John R. Kasich, Governor 

Mary Taylor, Lt. Governor 

ScottJ. Nally, Director 

DEC 0 7 2012 

Susan Hedman 

Regional Administrator 

U.S. EPA, Region 5 

77 West Jackson Blvd. R-19J 

Chicago, Illinois 60604-3507 

Re: Request for Review and Approval of the Revised Wheeling, WV-OH Area Maintenance 

Plan Approval for the 1997 Eight-Hour Ozone Standard 

Dear Administrator Hedman: 

I am writing to formally request review and approval of a revision to the maintenance plan for 

the Ohio portion of the Wheeling, WV-OH area (Belmont County) with respect to the 1997 

eight-hour ozone standard. Ohio EPA. submitted a redesignation request and maintenance 

plan for this area on June 20, 2006. U.S. EPA approved this requests on May 16, 2007 (72 

FR 27644). 

Ohio EPA is now requesting a revision to the maintenance plan to update mobile emission 

projections and conformity budgets based on emission rates generated from U.S. EPA's 

latest mobile emissions model, the Motor Vehicle Emission Simulation (MOVES) 2010. In 

December 2009, MOVES replaced MOBILE6.2 as the U.S. EPA's official emission factor 

model. The area is still attaining and maintaining the 1997 8-hour ozone standard and the 

point, area and non-road emissions have not changed significantly and did not need to be 

updated for this submittal. 

The enclosed information was compiled by Ohio EPA, Ohio Department of 

Transportation, West Virginia Department of Environmental Protection and Belomar 

Regional Council. The public hearing for this package was held on November 20, 2012 

in Bellaire, Ohio. No testimony was provided, nor were any comments received. 

This submittal consists of one (1) hard copy of the required documentation. An exact duplicate 

electronic version of the submittal in PDF format is available at 

http://epa.ohio.gov/dapc/SI P/1997 .aspx under the heading" Redesignations and Maintenance 

Plans". 

50 West Town Street • Suite 700 • P.O. Box 1049 • Columbus, OH 43216-1049 

www.epa.ohio.gov •(614) 644-3020 •(614) 644-3184(fax) 
If you have any questions, please contact Jennifer Dines in the Division of Air Pollution 

Control at (614) 644-3696. 

Sincerely, 

~y Director 

enclosures 

cc: Bob Hodanbosi, DAPC 

Jennifer Dines, DAPC 
 

REQUEST FOR REDESIGNATION AND 

MAINTENANCE PLAN FOR THE OHIO 

PORTION OF THE WHEELING, WV-OH 

EIGHT-HOUR OZONE 

NONATTAINMENT AREA 

Belmont County, Ohio

(Wheeling, WV-OH: Belmont County) 

Developed By: 

Ohio Environmental Protection Agency 

Division of Air Pollution Control in collaboration with 

West Virginia Department of Environmental 

Protection 

June 20, 2006

Revised December 2012
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 i 

TABLE OF CONTENTS 

Chapter One 

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

Background ................................................................................................................................... 1 

Geographical description .............................................................................................................. 2 

Status of air quality ....................................................................................................................... 2 

Chapter Two 

Requirements for redesignation .................................................................................................... 3 

Chapter Three 

Ozone monitoring .......................................................................................................................... 6 

Ambient data quality assured ........................................................................................................ 7 

Three complete years of data ....................................................................................................... 7 

Commitment to continue monitoring ............................................................................................. 9 

Chapter Four 

Emission Inventory ...................................................................................................................... 11 

Base Year Inventory ................................................................................................................... 11 

Emission Projections ................................................................................................................... 12 

Demonstration of Maintenance ................................................................................................... 17 

Permanent and Enforceable Emissions Reductions ................................................................... 22 

Provisions for Future Updates .................................................................................................... 23 

Chapter Five 

Control measures and regulations .............................................................................................. 24 

Implementation of Past SIP Revisions ........................................................................................ 24 

New Source Review Provisions ................................................................................................. 26 

Controls to remain in effect ......................................................................................................... 26 

Assurance of continued controls ................................................................................................. 26 

Chapter Six 

Contingency measures ............................................................................................................... 28 

Commitment to revise plan ......................................................................................................... 28 

Commitment for contingency measures ..................................................................................... 28 

Potential contingency measures ................................................................................................. 29 

List of VOC and NOx sources...................................................................................................... 30 

Chapter Seven 

Public participation ...................................................................................................................... 32 

Chapter Eight 

Conclusions ................................................................................................................................ 33 
 ii 

FIGURES 

Figure 1 Map of monitor locations for Wheeling, WV-OH: Belmont County 2002 – 2004.....6 

Figure 2 Map of monitor locations for Wheeling, WV-OH: Belmont County 2003 – 2005.....7 

TABLES 

Table 1 Monitoring Data for Wheeling, WV-OH: Belmont County 2002 – 2004 ................ 8 

Table 2 Monitoring Data for Wheeling, WV-OH: Belmont County 2003 - 2005 ................. 9 

Table 3 Emission Estimations for On-road Mobile Sources for Belmont Co. Ohio ........... 15 

Table 4 Emission Estimations for On-road Mobile Sources for Ohio Co. WV .................. 15 

Table 5 Emission Estimations for On-road Mobile Sources for Marshall Co. WV ............ 15 

Table 6 Combined Emission Estimations for On-Road Sources ...................................... 16 

Table 7 Mobile Vehicle Emission Budget Belmont Co. .................................................... 16 

Table 8 VOC Emission Inventory Belmont Co. Ohio ........................................................ 18 

Table 9 VOC Emission Inventory Marshall Co and Ohio Co. WV .................................... 18 

Table 10 Wheeling, WV: VOC Emission Inventory Totals .................................................. 19 

Table 11 NOx Emission Inventory Belmont Co. Ohio ......................................................... 19 

Table 12 NOx Emission Inventory Marshall Co and Ohio Co. WV ..................................... 20 

Table 13 Wheeling, WV: NOx Emission Inventory Totals ................................................... 20 

Table 14 Projected Emission Estimates 2004-2018 Belmont Co. Ohio ............................. 21 

Table 15 Projected Emission Estimates 2004-2018 Marshall Co and Ohio Co. WV .......... 21 

Table 16 Combined Projected Emission Estimates 2004-2018 ........................................ 21 

Table 17 Combined Comparison of 2002 and 2004 On-road and EGU Totals .................. 23 

 

APPENDICES 

A Aerometric Information Retrieval System (AIRS) Data 

B Emission Inventories 

C Emissions Analysis Method 

D Public Participation Documentation 
 iii 

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 1 

REQUEST FOR REDESIGNATION AND 

MAINTENANCE PLAN FOR THE OHIO PORTION OF THE 

WHEELING, WV-OH 

EIGHT-HOUR OZONE NONATTAINMENT AREA 

Wheeling, WV–OH: Belmont County 

CHAPTER ONE 

Introduction 

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

Standard (NAAQS) for ozone to develop State Implementation Plans (SIP’s) to 

expeditiously attain and maintain the standard. In 1997, the United States Environmental 

Protection Agency (U.S. EPA) revised the air quality standards for ozone replacing the 

1979 one-hour standard with an eight-hour ozone standard set at 0.08 parts per million 

(ppm). The standard was challenged legally and upheld by the U.S. Supreme Court in 

February of 2001. 

On April 15, 2004, U.S. EPA designated 134 nonattainment areas for the eight-hour ozone 

standard. Since that time, U.S. EPA has reclassified nine of the 134 original nonattainment 

areas to the next lower classification. Section 107(d)(3)(E) of the CAA allows states to 

request nonattainment areas be redesignated to attainment providing certain criteria are 

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

from nonattainment to attainment: 

i) A determination that the area has attained the eight-hour ozone standard.

ii) An approved State Implementation Plan (SIP) for the area under Section 

110(k).

iii) A determination that the improvement in air quality is due to permanent 

and enforceable reductions in emissions resulting from implementation of 

the SIP and other federal requirements.

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

v) A determination that all Section 110 and Part D requirements have been 

met. 

 

Background 

Belmont County, Ohio, Marshall and Ohio Counties in WV form the Wheeling-Belmont, WVOH interstate nonattainment area and constitute the Wheeling Metropolitan Statistical Area. 

 As part of the 1990 CAA Amendments re-evaluation, the Wheeling, WV-OH: Belmont 

County area was designated as Unclassifiable/Attainment for the one-hour ozone standard 

pursuant to the CAA and therefore, has not previously been subject to nonattainment area 

rule-makings. As a result of the 2004 ozone designations, U.S. EPA designated Wheeling, 

WV-OH: Belmont County basic nonattainment and subject to the eight-hour ozone 

requirements, including development of a plan to reduce volatile organic compounds 
 2 

(VOCs) and oxides of nitrogen (NOx) emissions and a demonstration that the area will meet 

the federal eight-hour air quality standard for ozone by June 2009. 

This document is intended to support Ohio’s request that Wheeling, WV-OH: Belmont 

County area be redesignated from nonattainment to attainment for the eight-hour ozone 

standard. Monitoring data for the Wheeling, WV area, including Belmont County, OH, have 

recorded three (3) years of complete, quality-assured ambient air quality monitoring data 

for the years 2002 – 2004 demonstrating attainment of the eight-hour ozone standard. In 

addition, the three-year period 2003 – 2005 continues to demonstrate attainment of the 

eight-hour standard. 

 Geographical Description

Belmont County is located in eastern Ohio and contains the city of St. Clairsville. Belmont 

County is bordered by Harrison County to the north, Monroe to the south, Guernsey and 

Noble to the west and Ohio and Marshall Counties in West Virginia to the east. This area is 

shown in Figure 1. 

 Status of Air Quality 

Ozone monitoring data for the three (3) years, 2002 through 2004, demonstrates that the 

air quality has met the NAAQS for ozone in this basic nonattainment area. The most recent 

three-year period, 2003 through 2005, continues to demonstrate attainment of the 

standard. The NAAQS attainment, accompanied by decreases in emission levels 

discussed in Chapter four, supports a redesignation to attainment for Wheeling, WV-OH: 

Belmont County based on requirements in Section 107(d)(3)(E) of the CAA. 
 3 

CHAPTER TWO 

Requirements for Redesignation 

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

Processing Requests to Redesignate Areas to Attainment (redesignation guidance), issued 

September 4, 1992, to Regional Air Directors. This request for redesignation and 

maintenance plan is based on the redesignation guidance, supplemented with additional 

guidance received from staff of U.S. EPA Region V. 

Below is a summary of each redesignation criterion as it applies to Wheeling, WV-OH: 

Belmont County. 

i.) Attainment of the standard: 

 There are two components involved in making this demonstration. The first 

component relies on ambient air quality data. The data that are used to 

demonstrate attainment should be the product of ambient monitoring that is 

representative of the area of highest concentration. The data should be 

collected and quality-assured in accordance with 40 CFR 58 and recorded in 

the Aerometric Information Retrieval System (AIRS) in order for it to be 

available to the public for review. 

 The second component relies upon supplemental U.S. EPA-approved air 

quality modeling. The supplemental modeling is not required for ozone 

nonattainment areas seeking redesignation. Therefore, this ozone 

redesignation request for Wheeling, WV-OH: Belmont County does not 

include modeling data. However, in Appendix C the most recent modeling 

results showing future attainment and maintenance are provided. Chapter 

three discusses this requirement in more detail and provides the attainment 

demonstration. 

ii.) SIP approval: 

 The SIP for the area must be fully approved under Section 110(k) and must 

satisfy all requirements that apply to the area. Ohio’s SIP was approved on 

May 9, 1994 (59FR23799) March 23, 1995 (60FR15235) and includes 

Wheeling, WV-OH: Belmont County. Chapter five discusses this 

requirement in more detail and provides the attainment demonstration. 

iii.) Permanent and enforceable improvement in air quality: 

 The state must be able to reasonably attribute the improvement in air quality 

to emission reductions which are permanent and enforceable. The state 

should estimate the percent reduction achieved from federal measures as 

well as control measures that have been adopted and implemented by the 

state. 
 4 

 Wheeling, WV-OH: Belmont County was not designated nonattainment for 

ozone as part of the 1990 CAA Amendments re-evaluation. As a result, Ohio 

has not adopted or implemented control measures beyond the federal 

measures, the initial 1979 statewide rules and those 1994 and 1995 rules 

which applied to “rural” attainment areas. Chapters four and five discuss this 

requirement in more detail and provide the attainment demonstration. 

iv.) Section 110 and Part D requirements: 

 For purposes of redesignation, a state must meet all requirements of Section 

110 and part D that were applicable prior to submittal of the complete 

redesignation request. 

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

designated nonattainment based on a violation of the NAAQS. 

 i.) Section 172(c) requirements 

 This section contains general requirements for nonattainment plans. 

The requirements for reasonable further progress, identification of 

certain emissions increases, and other measures needed for 

attainment will not apply for redesignations because they only have 

meaning for areas not attaining the standard. The requirements for an 

emission inventory will be satisfied by the inventory requirements of 

the maintenance plan. 

 ii.) Conformity 

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

consistent with section 176(c)(4) conformity requirements. The 

redesignation request should include conformity procedures, if the 

state already has these procedures in place. If a state does not have 

conformity procedures in place at the time that it submits a 

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

conformity regulation upon issuance, as applicable. Chapter five 

discusses this requirement in more detail and provides the attainment 

demonstration. 

v.) Maintenance plans. 

 Section 107(d)(3)(E) stipulates that for an area to be redesignated, U.S. EPA 

must fully approve a maintenance plan which meets the requirements of 

Section 175(A). The maintenance plan will constitute a SIP revision and 

must provide for maintenance of the relevant NAAQS in the area for at least 

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

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

such maintenance. 
 5 

In addition, the maintenance plan shall contain such contingency measures 

as the Administrator deems necessary to ensure prompt correction of any 

violation of the NAAQS. At a minimum, the contingency measures must 

include a requirement that the state will implement all measures contained in 

the nonattainment SIP prior to redesignation. 

States seeking redesignation of a nonattainment area should consider the 

following provisions: 

 a.) attainment inventory; 

 b.) maintenance demonstration; 

 c.) monitoring network; 

 d.) verification of continued attainment; and 

 e.) contingency plan. 

 

 Chapter six discusses this requirement in more detail and provides the 

attainment demonstration. 
 6 

CHAPTER THREE 

OZONE MONITORING

CAA Section107 (d)(3)(E)(i) 

Requirement 1 of 4: 

A demonstration that the NAAQS for ozone, as published in 40 CFR 50.4, has been 

attained. Ozone monitoring data must show that violations of the ambient standard are no 

longer occurring. 

Background: 

 There are no monitors measuring ozone concentrations in Belmont County. 

As shown in Figure 1 the two monitors used for measuring ozone 

concentrations for Belmont County in 2002 thru 2004 are located in Ohio 

County in West Virginia. The monitors are operated by the West Virginia 

Department of Environmental Protection (DEP), Division of Air Quality (DAQ), 

Northern Panhandle Regional Office. Figure 2 shows the location of the 

monitor locations for 2003 thru 2005. See Requirement 3 of 4 Demonstration 

section in this chapter for an explanation of the monitor relocation. 

Demonstration: 

Figure 1 Map of monitor locations for Wheeling, WV-OH: Belmont 

 County (2002 – 2004)
 7 

 Figure 2 Map of monitor locations for Wheeling, WV-OH: Belmont 

 County (2003 – 2005)

Requirement 2 of 4: 

Ambient monitoring data quality assured in accordance with 40 CFR 58.10, recorded in the 

U.S. EPA air quality system (AQS) database, and available for public view. 

Demonstration: 

WV has quality assured all data shown in Appendix A in accordance with 40 

CFR 58.10 and all other federal requirements. WV has recorded the data in 

the AQS database and therefore data are available to the public. 

Requirement 3 of 4: 

A showing that the three-year average of the fourth highest values, based on data from all 

monitoring sites in the area or its affected downwind environs, are below 85 parts per billion 

(ppb). This showing must rely on three (3) complete, consecutive calendar years of quality 

assured data 
 8 

Background: 

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

Handling Conventions for the eight-hour Ozone National Ambient Air Quality 

Standard (NAAQS)," U.S. EPA-454/R-98-017, December 1998. 

Three (3) complete years of ozone monitoring data are required to 

demonstrate attainment at a monitoring site. The eight-hour primary and 

secondary ozone ambient air quality standards are met at an ambient air 

quality monitoring site when the three-year average of the annual fourthhighest daily maximum eight-hour average ozone concentration is less than 

or equal to 0.08 ppm. When this occurs, the site is said to be in attainment. 

Three (3) significant digits must be carried in the computations. Because the 

third decimal digit, in ppm, is rounded, 0.084 ppm is the largest concentration 

that is less than or equal to 0.08 ppm. Therefore, for the purposes of this 

request, the eight-hour standard is considered to be 0.085 ppm. Values 

below 0.085 ppm meet the standard, values equal to or greater than 0.085 

ppm exceed the standard. These data handling procedures are applied on 

an individual basis at each monitor in the area. An area is in compliance with 

the eight-hour ozone NAAQS if, and only if, every monitoring site in the area 

meets the NAAQS. An individual site's three (3) year average of the annual 

fourth highest daily maximum eight-hour average ozone concentration is also 

called the site's design value. Table 1 shows the monitoring data for 2002 – 

2004 and Table 2 shows the monitoring data for 2003-2005 at the 

nonattainment area sites and was retrieved from the U.S. EPA AQS. 

Demonstration: 

 A listing of the four (4) highest readings from 2002 through 2004 is shown in 

Table 1 and readings from 2003-2005 are shown in Table 2. These readings 

were retrieved from the U.S. EPA air quality system (AQS.) 

Table 1: Monitoring Data for Wheeling, WV-OH: Belmont County 2002 – 

 2004 

Data source: U.S. EPA Air Quality System (AQS). 

 http://www.epa.gov/ttn/airs/airsaqs/index.htm

 

 1st 2nd 3rd 4th 2002-2004 

SITE ID COUNTY ADDRESS YEAR %OBS 8-HR 8-HR 8-HR 8-HR AVERAGE 

54-069-0007 OHIO (WV) NORTHERN PANH 2002 100 .099 .097 .097 .097 

54-069-0007 OHIO (WV) NORTHERN PANH 2003 99 .111 .097 .085 .076 

54-069-0009 OHIO (WV) WHEELING EPA 2004 100 .076 .072 .067 .063 

0.78 ppm 
 9 

Table 2: Monitoring Data for Wheeling, WV-OH: Belmont County 2003 – 

 2005 

Data source: U.S. EPA Air Quality System (AQS). 

 http://www.epa.gov/ttn/airs/airsaqs/index.htm

 1st 2nd 3rd 4th 2003-2005 

SITE ID COUNTY ADDRESS YEAR %OBS 8-HR 8-HR 8-HR 8-HR AVERAGE 

54-069-0007 OHIO (WV) NORTHERN PANH 2003 99 .111 .097 .085 .076 

54-069-0009 OHIO (WV) WHEELING EPA 2004 100 .076 .072 .067 .063 

54-069-0010 OHIO (WV) WARWOOD WATER 2005 100 .097 .097 .091 .089 

0.76 ppm 

Seasonal ozone monitoring at Wheeling, WV site number 54-069-0007 

began in 1982 and continued until the end of the 2003 ozone season due to 

the relocation of the WV Division of Air Quality (DAQ) Northern Panhandle 

Regional Office. While a long term replacement for the Wheeling ozone 

monitoring site was being established, an interim site (number 54-069-0009) 

was established in Wheeling for the 2004 ozone monitoring season. This 

interim site was located approximately four miles south of the original 

(number 54-069-0007.) A new Wheeling monitoring site, number 54-069-

0010 was installed in late 2004. This monitor is located approximately three 

tenths of a mile south of the original site (number 54-069-0007) and was 

operational for the 2005 ozone season. 

 Data from the interim site would need to have shown a 4th highest eight-hour 

ozone average of 0.082 ppm in 2004 for the three year average ozone 

concentration to violate the NAAQS for the period 2002-2004. An 

examination of the data from the other ozone monitoring sites also 

demonstrates that none of these locations exceeded an ozone average of 

0.082 ppm. 

The area's design value has trended downward as emissions have declined 

due to such factors as cleaner automobiles and fuels both regionally and 

locally. U.S. EPA’s rule to control nitrogen oxides from specific source 

categories (40 CFR Parts 51, 72, 75 and 96, published on October 17, 1998 

and referred to as the NOx SIP Call) has significantly reduced emissions from 

large electric generating units (EGUs), industrial boilers, and cement kilns. 

Ohio's NOx Budget Trading Program rule was approved on May 25, 2004 

[Ohio Administrative Code (OAC) Chapter 3745-14]. It is expected that this 

downward trend will continue as the above programs continue and some 

form of the U.S. EPA Clean Air Interstate Rule (CAIR) is implemented. 

Requirement 4 of 4: 

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

monitoring network to verify the maintenance of the attainment status. 
 10 

Demonstration: 

 WV commits to continue monitoring ozone levels at the sites indicated in 

Figure 2. WV will consult with U.S. EPA Region III staff prior to making 

changes to the existing monitoring network, should changes become 

necessary in the future. WV will continue to quality assure the monitoring 

data to meet all federal requirements. WV will enter all data into AQS on a 

timely basis in accordance with federal guidelines. 
 11 

CHAPTER FOUR 

EMISSION INVENTORY

CAA Section107 (d)(3)(E)(iii) 

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

ozone precursor emissions (VOC and NOx) representative of the year when the area 

achieves attainment of the ozone air quality standard. Ohio also must demonstrate that the 

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

attainment was achieved is based on permanent and enforceable emission reductions. 

Other emissions inventory related requirements include a projection of the emission 

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

projected level of emissions is sufficient to maintain the ozone standard; and a commitment 

to provide future updates of the inventory to enable tracking of emission levels during the 

10 year maintenance period. 

Requirement 1 of 5: 

A comprehensive emission inventory of the precursors of ozone completed for the base 

year. 

Background: 

The point source data are taken from Ohio's annual emissions reporting 

program. The 2002 periodic inventory has been identified as the preferred 

data base for SIP development and does coincide with nonattainment air 

quality in Wheeling, WV-OH: Belmont County. 

As part of the NOx SIP Call, many states, including Ohio were required to 

adopt into their rules a budget for all large EGUs. Ohio’s budget is adopted 

at OAC Chapter 3745-14. The budget represents a statewide cap on NOx

emissions. These emissions, capped by the state rule, should remain at or 

near this level through the maintenance period covered by this request. 

Periodic inventories, which include emissions from all sectors - mobile, area, 

non-road, and point sources - are prepared every three (3) years. 

Demonstration: 

While ozone and its precursors are transported into this region from outside 

areas, this information does provide some indication of the impact from Ohio 

sources near the nonattainment area. The emissions are decreasing 

substantially in response to regional and national programs affecting many 

EGUs such as the Acid Rain program and the NOx SIP Call. Other sectors of 

the inventory also impact ozone formation, but large regional sources such 

as EGUs have a substantial impact on the formation of ozone. 
 12 

Requirement 2 of 5: 

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

Background: 

Ohio EPA prepared a comprehensive inventory for Belmont County, including 

area, mobile, and point sources for precursors of ozone (VOCs and NOx) for 

base year 2002. The information below describes the procedures Ohio EPA 

used to generate the 2002 base inventories. These inventories were 

provided to Lake Michigan Air Directors Consortium (LADCO) and have been 

processed to develop summer day emissions for use in the air quality 

analyses. These processed modeling inventories have been identified as the 

correct iteration of the inventory for use in the redesignation. In this 

document, references to LADCO include the Midwest Regional Planning 

Organization. 

• Area sources were taken from the Ohio 2002 periodic inventory 

submitted to U.S. EPA. These projections were made from the U.S. 

Department of Commerce Bureau of Economic Analysis (BEA) growth 

factors, with some updated local information. 

• Mobile source emissions were calculated from MOVES 2010 

produced emission factors. 

• Point source information was compiled from Ohio EPA’s 2002 annual 

emissions inventory database and the 2002 U.S. EPA Air Markets 

acid rain database1

. 

• Biogenic emissions are not included in these summaries. 

• Non-road emissions were generated using U.S. EPA’s National Mobile 

Inventory Model (NMIM) 2002 application. To address concerns 

about the accuracy of some of the categories in U.S. EPA’s non-road 

emissions model, LADCO contracted with two (2) companies to 

review the base data and make recommendations. One of the 

contractors also estimated emissions for three (3) non-road categories 

not included in U.S. EPA’s non-road model. Emissions were estimated 

for aircraft, commercial marine vessels and railroads. Recreational 

motorboat population and spatial surrogates (used to assign 

emissions to each county) were significantly updated. The 

populations for the construction equipment category were reviewed 

and updated based upon surveys completed in the Midwest and the 

temporal allocation for agricultural sources also was updated. 

 

1 http://www.epa.gov/airmarkets/acidrain 
 13 

Demonstration: 

On-Road Emission Estimations 

In coordination with the Belmont, Ohio, Marshall Regional Council 

Metropolitan Planning Organization (Bel-O-Mar) and the West Virginia 

Department of Transportation (WVDOT), the Ohio Department of 

Transportation (ODOT) utilizes a regional travel demand forecast model to 

simulate traffic in the area and to forecast traffic flows for given growth 

expectations. The model is primarily used as a long range planning tool to 

evaluate the transportation system including determination of locations where 

additional travel capacity may be needed and to determine the infrastructure 

requirements necessary to meet that need. It is also used as a tool for air 

quality purposes to estimate the total emissions of pollution caused by 

vehicles in the area. The travel demand forecasting model is used to predict 

the total daily vehicle miles traveled (VMT) and an EPA computer program 

called MOVES2010 is used to calculate emissions per mile. The product of 

these is the total amount of pollution emitted by the on-road vehicles for the 

particular analyzed area. 

Overview 

Broadly described, MOVES2010 is used to generate “emission factors”, 

which are the average emissions per mile (grams/mile) for ozone precursors, 

NOx and VOC. The MOVES2010 model includes a number of variables that 

affect the emission factors. These variables have national default values, 

some of which require modification to reasonably reflect local conditions. 

Some of these variables are discussed here. The source types are traveling 

on road types (MOVES2010 road types are Rural Restricted Access, Rural 

Unrestricted Access, Urban Restricted Access, and Urban Unrestricted 

Access). The vehicle speeds also affect the emission factor values. 

Meteorological conditions such as air temperature and humidity has a 

significant effect on emission factors. Emission factors produced by 

MOVES2010 can also include the effect of emission reduction strategies 

such as vehicle inspection and maintenance programs, regulation of fuels, 

etc. These MOVES2010 inputs are estimated using the best available data. 

These inputs are reviewed and agreed to by EPA and transportation 

agencies in a formal interagency consultation process. Emission factors are 

multiplied by VMT from the travel demand model to estimate the total vehicle 

emissions. 

The emission factors from MOVES2010 can be used with the travel demand 

model information by combining the disaggregate emission rates with VMT, 

and source type population for each road type, source type and hour of day, 

and then sum them up to get the total emissions for the area. 
 14 

The Bel-O-Mar analysis method, developed by ODOT, is to aggregate the 

emission rates by two source types (cars & trucks), then applying VMT and 

source type population, thereby reducing the intensive processes. In the first 

step emission factors are broadly classified into total vehicles, cars and 

trucks by pollutant, by average speed, road type and hour of day. Then the 

hourly link volumes generated from travel demand model are combined with 

emission factors for each network link for each hour. The on-road vehicle 

emissions for the area are the sum of all individual link-hour emissions. 

Vehicle-based emissions are obtained by the combination of corresponding 

emission factors and source type population. Intrazonal emissions are 

computed using a separate method to account for those trips that use local 

roads to travel within a zone. Intrazonal VMT is combined with corresponding 

emission factors to get intrazonal emissions. Total emissions are sum of onroad vehicle emissions, vehicle-based emissions and intrazonal emissions. 

Automated programs, using FORTRAN and CUBE scripting, were developed 

by ODOT to generate total emissions. The process uses data on daily and 

directional traffic distributions as well as more up to date volume/delay 

functions from the 2000 Highway Capacity Manual (HCM). This process also 

handles the newer model network formats and MOVES generated emission 

factors 

Best Available Data 

Most current vehicle age distribution data, temperature data, fuel properties 

data, and source type distribution data provided by ODOT’s ATRs and WIMs, 

NOAA, ODPS, and Ohio EPA were used by the ODOT for generating 

emission factors. Likewise, the most current transportation planning data 

available from Bel-O-Mar and most current ODOT count data were used for 

the emissions estimates. 

Analysis Years 

Analysis years for this re-designation request include 2002, 2004, 2009, and 

2018 to meet the requirements specified by the CAA and EPA. The travel 

demand model presents the transportation system conditions for each of 

these years. Model runs for each future analysis year contain the road 

network Bel-O-Mar and ODOT expects to exist at the beginning of that year 

with corresponding socioeconomic forecasts for that year. 

Local Road VMT 

Most local roads such as subdivision streets are not explicitly modeled in a 

travel demand model. These local roads are represented as fictitious 

roadways called centroid connectors. Local road VMT is included in the 

ODOT post process by including the traffic loaded on centroid connectors. In 

addition, some local road traffic is captured as intra-zonal trips which travel 

demand models usually do not assign to roadway segments. The ODot post 

process includes these trips as local road VMT. 
 15 

Emission Estimations 

Tables 3 through 5 contain the results of the emissions analysis for the 

appropriate years. 

Table 3 Emission Estimations for On-Road Mobile Sources for 

 Belmont County, Ohio 

 Data source: On-road only, Ohio DOT Modeling and Forecasting Section.

Belmont County - Ohio 2002 2004 2009 2018 

VMT (miles/day) 2,675,185 2,658,945 2,720,328 2,822,495 

VOC (tons/day) 5.39 5.04 3.76 1.72 

NOx (tons/day) 14.99 13.98 10.64 4.14 

Table 4 Emission Estimations for On-Road Mobile Sources for Ohio 

County, WV 

Data source: On-road only, Ohio DOT Modeling and Forecasting Section.

Ohio County, WV 2002 2004 2009 2018 

VMT (miles/day) 1,291,256 1,317,716 1,743,104 1,722,611 

VOC (tons/day) 2.11 1.96 1.50 0.66 

NOx (tons/day) 6.65 5.63 4.42 1.46 

Table 5 Emission Estimations for On-Road Mobile Sources for 

 Marshall County, WV 

Data source: On-road only, Ohio DOT Modeling and Forecasting Section.

Marshall County, WV 2002 2004 2009 2018 

VMT (miles/day) 845,952 774,247 819,606 852,369 

VOC (tons/day) 1.40 1.24 0.86 0.39 

NOx (tons/day) 2.99 2.48 1.86 0.69 
 16 

Table 6 Combined VOC and NOx Emission Estimations for On-Road 

Mobile Sources for Belmont County, OH, Marshall and Ohio 

County, WV 

Data source: On-road only, Ohio DOT Modeling and Forecasting Section.

County VOC 2018 

Belmont County, OH VOC 1.72 

Marshall County, WV VOC 0.39 

Ohio County, WV VOC 0.66 

TOTAL 2.77 

NOx

Belmont County, OH NOx 4.14 

Marshall County, WV NOx 0.69 

Ohio County, WV NOx 1.46 

TOTAL 6.29 

Motor Vehicle Emission Budget 

Table 7 contains the motor vehicle emissions budget for Belmont County, 

Ohio. 

Table 7 Mobile Vehicle Emission Budget for Belmont County, OH 

Data source: Ohio DOT Modeling and Forecasting Section.

2009 2018 

VOC (tons/day 4.70 2.15 

NOx (tons/day) 13.30 5.18 

This budget includes the emission estimates calculated for 2018. The 

emission estimates are derived from the QRS travel demand model and 

MOVES 2010as described above under the expected Belmont-Ohio Marshall 

Regional Council Metropolitan Planning Organization (Bel-O-Mar) 2025 Long 

Range Plan. The mobile source budget for Belmont County includes 2.15 

tons/day for VOC and 5.18 tons/day for NOx. These correspond to a 25 

percent increase from the 2018 on-road emissions for both VOC and NOx. 

Appendix C contains data tables and graphs of these emissions. 

All methodologies, latest planning assumptions and the safety margins were 

determined through the interagency consultation process described in the 
 17 

Transportation Conformity Memorandum of Understanding (MOU) for Bel-OMar. 

Requirement 3 of 5: 

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

standard. 

Background: 

In consultation with U.S. EPA, Ohio EPA selected the year 2018 as the 

maintenance year for this redesignation request. This document contains 

projected emissions inventories for 2009 and 2018. Ohio DOT performed 

emission projections for Wheeling, WV-OH: Belmont County using the 

following approaches. 

• Mobile source emission projections are based on the U.S. EPA 

MOVES 2010 model. The analysis is described in more detail in 

Appendix C. All projections were made in accordance with 

“Procedures for Preparing Emissions Projections” U.S. EPA-45/4-91-

019. 

• Emissions inventories are required to be projected to future dates to 

assess the influence growth and future controls will have. LADCO 

developed growth and control files for point, area, and non-road 

categories. These files were used to develop the future year 

emissions estimates used in this document. This was done so the 

inventories used for redesignation are consistent with modeling 

performed in the future. 

The detailed inventory information for Belmont County for 2004, 2009 and 

2018 is in Appendix B. Emission trends are an important gauge for continued 

compliance with the ozone standard. Therefore, Ohio EPA performed an 

initial comparison of the inventories for the base year and maintenance 

years. Mobile source emission inventories are described in Appendix B. In 

addition to the LADCO estimates, point source emissions were projected 

based upon the statewide EGU NOx budgets from the Ohio NOx rule. 

Emission Inventories for Marshall and Ohio Counties in WV used for this 

request were developed by DEP staff with the support of the contractors for 

the Visibility Improvement State and Tribal Association of the Southeast 

(VISTAS), a federally recognized regional planning organization. 

The following tables include sectors Electrical Generating Unit (EGU-Point), 

Non-Electrical Generating Unit (Non-EGU), Non-road Mobile (Non-road), 

Other Area (Other), Marine, Aircraft, Rail (MAR), On-road Mobile (On-road). 

Please note that WV non-road sector includes MAR. 
 18 

Demonstration: 

Table 8 Belmont County, OH VOC Emission Inventory Totals for Base 

 Year 2002, Estimated 2004 and Projected 2009 and 2018 (tons 

 per day) 

Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air 

 Directors Consortium (LADCO) Web site:

http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm. 

Data source: On-road only, Ohio DOT Modeling and Forecasting Section 

Sector 2002 

Base 

2004 

Attainment

2009 

Interim 

2018 

Maintenance 

Safety 

Margin 

EGU Point 0.19 0.17 0.12 0.17 

Non-EGU 0.03 0.03 0.03 0.04 

Non-road 0.94 0.88 0.76 0.56 

Other 4.10 4.03 3.85 3.86 

MAR 0.05 0.05 0.05 0.05 

On-road 5.39 5.04 4.70* 2.15* 

TOTAL 10.70 10.20 9.51 6.83 3.37

 * includes 25 percent increase to the mobile source budget 

Table 9 Combined Marshall and Ohio County, WV VOC Emission 

 Inventory Totals for Base Year 2002, Estimated 2004 and 

 Projected 2009 and 2018 (tons per day) 

Data source: WV emission inventory, Visibility Improvement State and Tribal Association of the 

 Southeast (VISTAS) http://www.vistas-sesarm.org/. 

Data source: On-road only, Ohio DOT Modeling and Forecasting Section

Sector 2002 

Base 

2004 

Attainment 

2009 

Interim

2018 

Maintenance 

Safety 

Margin 

EGU Point 0.50 0.50 0.70 0.70 

Non-EGU 2.50 2.50 2.10 2.60 

Non-road (includes MAR) 2.30 2.30 2.10 1.80 

Other (Area) 14.80 15.40 7.30 8.40 

On-road Marshall 1.17 0.97 0.65 0.37 

On-road Ohio 2.11 1.96 1.50 0.66 

TOTAL 23.61 23.90 14.56 14.55 9.35 
 19 

Table 10 Wheeling, WV: VOC Emission Inventory Totals for Base Year 

2002, Estimated 2004 and Projected 2009 and 2018 (tons per day) 

Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air 

 Directors Consortium (LADCO) Web site: 

http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm. 

 Data source: WV emission inventory, Visibility Improvement State and Tribal Association of the 

 Southeast (VISTAS) http://www.vistas-sesarm.org/. 

Data source: On-road only, Ohio DOT Modeling and Forecasting Section. 

 2002 Base 2004 

Attainment 2009 Interim 

2018 Safety 

Maintenance Margin

Belmont Co. Ohio 

Total 10.70 10.20 9.51 6.83 

Marshall and Ohio 23.61 23.90 14.56 14.55 County WV Total 

COMBINED VOC 

TOTAL 34.31 34.10 24.07 21.38 12.72 

Table 11 Belmont County NOx Emission Inventory Totals for Base Year 

 2002, Estimated 2004 and Projected 2009 and 2018 (tons per 

 day) 

Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air 

 Directors Consortium (LADCO) Web site: 

http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm. 

Data source: On-road only, Ohio DOT Modeling and Forecasting Section

Sector 2002 

Base 

2004 

Attainment 

2009 

Interim 

2018 

Maintenance 

Safety 

Margin 

EGU Point 31.67 28.61 20.96 18.85 

Non-EGU 0.08 0.08 0.08 0.08 

Non-road 1.43 1.35 1.16 0.63 

Other 0.31 0.29 0.36 0.38 

MAR 1.61 1.54 1.38 1.28 

On-road 14.99 13.98 13.30* 5.18* 

TOTAL 50.09 45.85 37.24 26.40 19.46 

 * includes 25 percent increase to the mobile source budget 
 20 

Table12 Combined Marshall and Ohio County, WV NOx Emission 

 Inventory Totals for Base Year 2002, Estimated 2004 and 

 Projected 2009 and 2018 (tons per day) 

Data source: WV emission inventory, Visibility Improvement State and Tribal Association of the 

 Southeast (VISTAS) http://www.vistas-sesarm.org/. 

Data source: On-road only, Ohio DOT Modeling and Forecasting Section

Sector 2002 

Base 

2004 

Attainment 

2009 

Interim 

2018 

Maintenance 

Safety 

Margin 

EGU Point 133.50 73.20 51.1 14.9 

Non-EGU 18.70 12.6 10.6 11.3 

Non-road (includes MAR) 5.60 7.3 5.2 4.6 

Other (Area) 3.40 3.4 1.8 2.0 

On-road Marshall 1.60 1.35 0.92 0.38 

On-road Ohio 6.65 5.63 4.42 1.46 

TOTAL 170.84 104.61 74.98 34.95 69.66 

Table 13 Wheeling, WV: NOx Emission Inventory Totals for Base Year 

2002, Estimated 2004 and Projected 2009 and 2018 (tons per 

day) 

Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air 

 Directors Consortium (LADCO) Web site:

http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm. 

Data source: WV emission inventory, Visibility Improvement State and Tribal Association of the 

 Southeast (VISTAS) http://www.vistas-sesarm.org/. 

Data source: On-road only, Ohio DOT Modeling and Forecasting Section 

 2002 Base 2004 

Attainment 2009 Interim 2018 

Maintenance 

Safety 

Margin

Belmont Co. Ohio 

Total 50.09 45.85 

37.24 26.40 

Ohio and Marshall 

County WV Total 170.84 104.61 74.98 34.95 

COMBINED NOx

TOTAL 220.93 150.46 

112.22 61.35 89.12 
 21 

Table 14 Belmont County, OH Comparison of 2004 attainment year and 

2018 projected emission estimates (tons per day, summer) 

 Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air 

 Directors Consortium (LADCO) Web site:

http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm. 

 Data source: On-road only, Ohio DOT Modeling and Forecasting Section.

2004 2018 Projected Decrease 

VOC 10.20 6.83 3.37 

NOx 45.85 26.40 19.46 

Table 15 Marshall and Ohio County, WV Combined Comparison of 2004 

attainment year and 2018 projected emission estimates (tons 

per day, summer) 

Data source: WV emission inventory, Visibility Improvement State and Tribal Association of the 

 Southeast (VISTAS) http://www.vistas-sesarm.org/. 

Data source: On-road only, Ohio DOT Modeling and Forecasting Section.

2004 2018 Projected Decrease 

VOC 23.90 14.55 9.35 

NOx 104.61 34.95 69.66 

Table 16 Wheeling, WV-OH Combined Comparison of 2004 attainment 

year and 2018 projected emission estimates (tons per day, 

summer) 

 Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air 

 Directors Consortium (LADCO) Web site:

http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm. 

Data source: WV emission inventory, Visibility Improvement State and Tribal Association of the 

 Southeast (VISTAS) http://www.vistas-sesarm.org/. 

Data source: On-road only, Ohio DOT Modeling and Forecasting Section

2004 2018 Projected 

Decrease 

Combined VOC Total 34.10 21.38 12.72 

Combined NOx Total 150.46 61.35 89.12 

VOC emissions in the nonattainment area are projected to decrease by 12.72 

tons. Area source emissions and, to a lesser extent, point sources, show an 

increase due to expectations that the population will grow in this area. 

However, cleaner vehicles and fuels are expected to be in place in 2009 and 

2018 and result in an overall drop in VOC emissions. 
 22 

NOx emissions in the nonattainment area are projected to decrease by 89.12 

tons. Decreases from U.S. EPA rules covering Tier 2 Motor Vehicle 

Emissions Standards and Gasoline Sulfur Control Requirements2, Highway 

Heavy-Duty Engine Rule3 and Non-road Diesel Engine Rule4 also are 

factored into the changes. Further, due to implementation of the NOx SIP 

Call across the eastern United States, NOx and ozone levels entering this 

area also will be decreased. 

Requirement 4 of 5: 

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

attainment was achieved is based on permanent and enforceable emission reductions and 

not on temporary adverse economic conditions or unusually favorable meteorology. 

Background: 

Ambient air quality data from all monitoring sites indicate that air quality met 

the NAAQS for ozone in 2004. U.S. EPA’s redesignation guidance (p 9) 

states, “A state may generally demonstrate maintenance of the NAAQS by 

either showing that future emissions of a pollutant or its precursors will not 

exceed the level of the attainment inventory, or by modeling to show that the 

future mix of sources and emissions rates will not cause a violation of the 

NAAQS.” 

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

emissions information once every three (3) years or annually if VOC potential 

to emit is greater than 250 tons or NOx potential to emit is greater than 2500 

tons, in accordance with U.S. EPA’s Consolidated Emissions Reporting Rule 

(CERR). Ohio EPA prepares a new periodic inventory for all ozone precursor 

emission sectors every three (3) years. These ozone precursor inventories 

will be prepared for 2005, 2008, and 2011 as necessary to comply with the 

inventory reporting requirements established in the CFR. Emissions 

information will be compared to the 2002 base year and the 2018 projected 

maintenance year inventories to assess emission trends, as necessary, to 

assure continued compliance with the ozone standard. 

Demonstration: 

Permanent and enforceable reductions of VOCs and NOx have contributed to 

the attainment of the eight-hour ozone standard. Permittable emission 

reductions between 2002 and 2004 were due to the application of tighter 

federal standards on new vehicles. Also, Title IV of the CAA and the NOx

SIP Call required the reduction of oxides of nitrogen from utility sources. 

 

2 http://www.epa.gov/fedrgstr/EPA-AIR/2000/February/Day-10/a19a.htm 3 http://www.epa.gov/fedrgstr/EPA-AIR/1997/October/Day-21/a27494.htm 4 http://www.epa.gov/fedrgstr/EPA-AIR/1998/October/Day-23/a24836.htm 
 23 

Table 17 Wheeling, WV-OH: Combined Comparison of 2002 base year 

and 2004 attainment year on-road and EGU reductions 

Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air 

 Directors Consortium (LADCO) Web site:

http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm. 

Data source: WV emission inventory, Visibility Improvement State and Tribal Association of the 

 Southeast (VISTAS) http://www.vistas-sesarm.org/. 

Data source: On-road only, Ohio DOT Modeling and Forecasting Section.

2002 2004 Reduction 

On-road VOC 8.90 8.24 0.66 

On-road NOx 24.63 22.09 2.54 

EGU NOx 165.17 101.81 63.36 

Requirement 5 of 5: 

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

levels including an annual emission statement from major sources. 

Demonstration: 

As required by Section 175A(b) of the CAA, Ohio commits to submit to the 

Administrator, eight (8) years after redesignation, an additional revision of 

this SIP. The revision will contain Ohio's plan for maintaining the national 

primary ozone air quality standard for 10 years beyond the first 10 year 

period after redesignation. 
 24 

CHAPTER FIVE 

CONTROL MEASURES AND REGULATIONS

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

Requirement 1 of 4:

A U.S. EPA approved SIP control strategy that includes RACT requirements for existing 

stationary sources covered by Control Technology Guidelines (CTG) as applied in Ohio’s 

rural counties. 

Background: 

As required by Section 172 of the 1990 CAA Amendments, in the mid-1990’s 

Ohio promulgated rule requiring RACT for emissions of VOCs. There were 

no specific rules required by the CAA such as RACT for existing sources 

beyond statewide rules. 

Demonstration: 

Statewide RACT rules have been applied to all new sources locating in Ohio 

since that time. The Ohio rules are found in OAC Chapter 3745-21. 

 

Requirement 2 of 4:

Evidence that control measures required in past ozone SIP revisions have been fully 

implemented. 

Background: 

The U.S. EPA NOx SIP Call required 22 states to pass rules that would result 

in significant emission reductions from large EGUs, industrial boilers, and 

cement kilns in the eastern United States. Ohio passed this rule in 2001. 

Beginning in 2004, this rule will account for a reduction of approximately 31 

percent of all NOx emissions statewide compared to previous uncontrolled 

years. The other 21 states also have adopted these rules. 

Demonstration: 

U.S. EPA and Ohio EPA performed modeling that indicated this area would 

attain the eight-hour ozone standard with the implementation of the NOx SIP 

Call. Controls for EGUs 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 U.S. EPA 

Clean Air Markets Web site, quantifies the gradual NOx reductions that have 

occurred in Ohio as a result of Title IV of the 1990 CAA Amendments and the 

beginning of the NOx SIP Call Rule. Ohio developed the NOx Budget Trading 

Program rules in OAC Chapter 3745-14 in response to the SIP Call. OAC 

chapter 3745-14 regulated EGUs and certain non-EGUs under a cap and 

trade program based on an 85 percent reduction of NOx emissions from 
 25 

EGUs and a 60 percent reduction of NOx emissions from non-EGUs, 

compared to historical levels. This cap will stay in place through 2008, at 

which time the CAIR program will supersede it. 

U.S. EPA has recently published Phase II of the NOx SIP Call that 

establishes a budget for large (greater than 1 ton per day emissions) 

stationary internal combustion engines. Ohio EPA’s proposed rule OAC 

3745-14-12 addresses stationary internal combustion engines, all used in 

natural gas pipeline transmissions. An 82 percent NOx reduction from 1995 

levels is anticipated. Completion of the compliance plan is expected by May 

1, 2006 and the compliance demonstration will begin May 1, 2007. The 

2007 controlled NOx emissions will be 599 tons per day. 

Tier II Emission Standards for Vehicles and Gasoline Sulfur Standards 

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

emissions from cars and light trucks, including sport utility vehicles (SUVs). 

Under this proposal, automakers will be required to sell cleaner cars, and 

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

will apply nationwide. The federal rules will phase in between 2004 and 

2009. U.S. EPA has estimated that NOx emission reductions will be 

approximately 77 percent for passenger cars, 86 percent for smaller SUVs, 

light trucks, and minivans, and 65 to 95 percent reductions for larger SUVs, 

vans, and heavier trucks. 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. 

Heavy-Duty Diesel Engines 

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

program which includes low-sulfur diesel fuel standards, which will be phased 

in from 2004 through 2007. This rule applies to heavy-duty gasoline and 

diesel trucks and buses. This rule will result in a 40 percent reduction in NOx

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

inventory. 

Clean Air Non-road Diesel Rule 

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

applies to diesel engines used in industries such as construction, agriculture, 

and mining. It also contains a cleaner fuel standard similar to the highway 

diesel program. The new standards will cut emissions from non-road diesel 

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

in this rule, currently accounts for 47 percent of diesel particulate matter (PM) 

and 25 percent of NOx from mobile sources nationwide. Sulfur levels will be 

reduced in non-road diesel fuel by 99 percent from current levels, from 

approximately 3,000 ppm now to 15 ppm in 2009. New engine standards 

take effect, based on engine horsepower, starting in 2008. 
 26 

Together, these rules will substantially reduce local and regional sources of 

ozone precursors. 

Requirement 3 of 4:

Acceptable provisions to provide for new source review. 

Background: 

Ohio has a long standing and fully implemented New Source Review (NSR) 

program. This is addressed in OAC Chapter 3745-31. The chapter includes 

provisions for the Prevention of Significant Deterioration (PSD) permitting 

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

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

approval on January 22, 2003 (68FR 2909) by U.S. EPA as part of the SIP. 

Demonstration: 

Any facility that is not listed in the 2002 emission inventory, or for the closing 

of which credit was taken in demonstrating attainment, will not be allowed to 

construct, reopen, modify, or reconstruct without meeting all applicable 

permit rule requirement. The review process will be identical to that used for 

new sources. Once the area is redesignated, Ohio EPA will implement the 

NSR through the PSD program. 

Requirement 4 of 4:

Assure that existing controls will remain in effect after redesignation unless the state 

demonstrates through photochemical modeling that the standard can be maintained without 

one (1) or more controls. 

Demonstration: 

Ohio commits to maintaining the aforementioned control measures after 

redesignation. Ohio hereby commits that any changes to its rules or 

emission limits applicable to VOC and/or NOx sources, as required for 

maintenance of the ozone standard in Wheeling, WV-OH: Belmont County, 

will be submitted to U.S. EPA for approval as a SIP revision. 

Ohio, through Ohio EPA’s Legal section, has the legal authority and 

necessary resources to actively enforce any violations of its rules or permit 

provisions. After redesignation, it intends to continue enforcing all rules that 

relate to the emission of ozone precursors in Wheeling, WV-OH: Belmont 

County. 
 27 

LADCO Modeling Analysis for 8-Hour Ozone Standard Assessment 

LADCO performed modeling to evaluate the effect of the NOx SIP Call and 

Tier II / Low Sulfur rule for future year 2007 ozone in the Lake Michigan area. 

 This modeling was originally designed to assess the one-hour ozone 

standard. Further analysis was conducted and documented in the LADCO’s 

White Paper “8-Hour Ozone Assessment” dated May 2, 2001. Base year 

design values used were the average of the design values for the three (3) 

three-year periods (1994-1996, 1995-1997, and 1996-1998). Base year 

emissions were taken from 1996 and four (4) ozone episodes were 

evaluated: June 22-28, 1991; July 14-21, 1991; June 13-25, 1995; and July 

7-18, 1995. 

While modeling results were not calculated for the Wheeling, WV-OH: 

Belmont County area, the average decrease in ozone from the base case 

modeling run with modeling runs that applied emission controls required by 

the Clean Air Act, NOx SIP Call and Tier II /low-sulfur requirements was 15 

ppb (2009 Future design value of 73.3ppb*.) [* Midwest RPO Base K 2009 

Future Base case with on-the-books” including CAIR]. 

 LADCO Modeling for CAIR of 2004 

On March 10, 2004, U.S. EPA promulgated CAIR. NOx emissions will be cut 

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

million tons in 2018 in 28 eastern states and the District of Columbia. 

LADCO performed modeling to support the associated emission reductions 

for CAIR. This modeling was based on 2001 – 2002 design values for the 

Wheeling, WV-OH: Belmont County area. Results of the CAIR modeling 

show Wheeling, WV-OH: Belmont County will continue to attain the eighthour ozone NAAQS well into the future. 
 28 

CHAPTER SIX 

CONTINGENCY MEASURES 

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

Requirement 1 of 4:

A commitment to submit a revised plan eight (8) years after redesignation. 

Demonstration: 

Ohio hereby commits to review its maintenance plan eight (8) years after 

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

Requirement 2 of 4:

A commitment to expeditiously enact and implement additional contingency control 

measures in response to exceeding specified predetermined levels (triggers) or in the event 

that future violations of the ambient standards occur. 

Demonstration: 

Ohio hereby commits to adopt and expeditiously implement necessary 

corrective actions in the following circumstances: 

 

Warning Level Response: 

A warning level response shall be prompted whenever an annual (1-year) 

fourth high monitored value of 88 ppb occurs in a single ozone season within 

the maintenance area. A warning level response will consist of a study to 

determine whether the ozone value indicates a trend toward higher ozone 

values or whether emissions appear to be increasing. The study will evaluate 

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

necessary to reverse the trend taking into consideration ease and timing for 

implementation as well as economic and social considerations. 

Implementation of necessary controls in response to a warning level 

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

later than 12 months from the conclusion of the most recent ozone season 

(September 30). 

Should it be determined through the Warning Level study that action is 

necessary to reverse the noted trend, the procedures for control selection 

and implementation outlined under action level response shall be followed. 

 

 Action Level Response 

An action level response shall be prompted whenever a two (2) year average 

fourth high monitored value of 85 ppb occurs within the maintenance area. In 

the event that the action level is triggered and is not due to an exceptional 

event, malfunction, or noncompliance with a permit condition or rule 

requirement, Ohio EPA will determine additional control measures needed to 
 29 

assure future attainment of NAAQS for ozone. In this case, measures that 

can be implemented in a short time will be selected in order to be in place 

within eighteen (18) months from the close of the ozone season that 

prompted the action level. 

 Control Measure Selection and Implementation 

Adoption of any additional control measures is subject to the necessary 

administrative and legal process. This process will include publication of 

notices, an opportunity for public hearing, and other measures required by 

Ohio law for rulemaking by state environmental boards. 

If a new measure/control is already promulgated and scheduled to be 

implemented at the federal or state level, and that measure/control is 

determined to be sufficient to address the upward trend in air quality, 

additional local measures may be unnecessary. Furthermore, Ohio will 

submit to U.S. EPA an analysis to demonstrate the proposed measures are 

adequate to return the area to attainment. 

Requirement 3 of 4:

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

Demonstration: 

In the event that a violation of the ozone NAAQS is measured such that 

nonattainment is indicated at any ozone monitor in the Wheeling-Belmont 

nonattainment area operated in accordance with 40 CFR Parts 53 and 58, 

WVDEP and Ohio EPA will accordingly select and adopt one or more 

measures from the list provided below to assure continued attainment. The 

selection of measures will be based on cost-effectiveness, emission 

reduction potential, economic and social considerations or other factors that 

WVDEP and Ohio EPA deems appropriate. WVDEP in conjunction with Ohio 

EPA will solicit input from all interested and affected persons in the 

maintenance area prior to selecting appropriate contingency measures. 

Because it is not possible at this time to determine what control measure will 

be appropriate at an unspecified time in the future, the list of contingency 

measures outlined below is not comprehensive. 

1) Extend the applicability of 45 CFR 21 (VOC/RACT rule) to include 

 source categories previously excluded (e.g. waste water treatment 

 facilities). 

2) Revise new source permitting requirements requiring more stringent 

emissions control technology and/or emissions offsets. 

3) NOx RACT requirements if necessary. 
 30 

4) Regulations to establish plant-wide emission caps (potentially with 

 emissions trading provisions). 

5) Stage II Vapor Recovery regulations. 

6) Establish a Public Awareness/Ozone Action Days Program, a twopronged program focusing on increasing the public’s understanding of 

air quality issues in the region and increasing support for actions to 

improve the air quality, resulting in reduced emissions on days when 

the ozone levels are likely to be high. 

One or more of these regulatory revisions would be selected within three (3) months 

after verification of a monitored violation within forty-five (45) days of occurrence. 

For each regulatory revision selected, a draft rule will be developed by WVDEP and 

Ohio EPA within six (6) months of selection. The WVDEP and Ohio EPA will file the 

draft rule as an emergency rule and will become effective within forty-two (42) days 

after filing and fully implemented within six (6) months after adoption. Rule(s) will be 

filed as a legislative rule(s) for permanent authorization by the Legislature during the 

following legislative session. Therefore, less than eighteen (18) months should 

elapse from the time a violation occurs until an appropriate control measure is fully 

implemented. 

No contingency measure shall be implemented without providing the 

opportunity for full public participation during which the relative costs and 

benefits of individual measures, at the time they are under consideration, can 

be fully evaluated. 

Requirement 4 of 4:

A list of VOC and NOx sources potentially subject to future controls. 

Demonstration: 

The following is a list of VOC and NOx sources potentially subject to future 

controls. 

NOx RACT 

• EGUs 

• asphalt batching plants 

• industrial/commercial and institutional boilers 

• process heaters 

• internal combustion engines 

• combustion turbines 

• other sources greater than 100 tons per year 
 31 

VOC RACT 

• consumer products 

• architectural and industrial maintenance coatings 

• stage I gasoline dispensing facilities (including pressure valves) 

• automobile refinishing shops 

• cold cleaner degreasers 

• portable fuel containers 

• synthetic organic compound manufacturing 

• organic compound batch processes 

• wood manufacturing 

• industrial wastewater 

• aerospace industry 

• shipbuilding 

• bakeries 

• plastic parts coating 

• volatile organic liquid storage 

• industrial solvent cleaning 

• offset lithography 

• industrial surface coating 

• other sources greater than 50 tons per year 
 32 

CHAPTER SEVEN 

PUBLIC PARTICIPATION

Ohio published a notification for a public hearing and solicitation for public comment 

concerning the draft redesignation petition and maintenance plan in a widely distributed 

publication over 30 days prior to the public hearing. 

The public hearing to receive comments on the redesignation request was held on 

November 20, 2012, at 330 32nd Street, Bellaire, Ohio. The public comment period closed 

on November 20, 2012. Appendix D includes a copy of the public notice and the transcript 

from the public hearing. 
 33 

CHAPTER EIGHT 

CONCLUSIONS

The Wheeling, WV-OH: Belmont County basic nonattainment area has attained the 

NAAQS standard and complied with the applicable provisions of the 1990 CAA 

Amendments regarding redesignations of basic ozone nonattainment areas. 

Documentation to that effect is contained herein. Ohio EPA has prepared a state 

implementation and maintenance plan that meets the requirement of Section 110 (a)(1) of 

the 1990 CAA. 

Ohio has performed an analysis that shows the air quality improvements are due to 

permanent and enforceable measures. In addition, significant regional NOx reductions will 

ensure continued compliance (maintenance) with the standard and that all CAA 

requirements necessary for redesignation have been met. 

Based on this presentation, the Wheeling, WV-OH: Belmont County ozone basic 

nonattainment area meets the requirements for redesignation under the CAA and U.S. EPA 

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

significant regional NOx reductions will ensure continued compliance (maintenance) with 

the standards with an increasing margin of safety. 

The State of Ohio hereby requests that the Wheeling, WV-OH: Belmont County ozone 

basic nonattainment area be redesignated to attainment simultaneously with U.S. EPA 

approval of the Ohio state implementation and maintenance plan provisions contained 

herein. 
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Synopsis of Changes 

Revised Wheeling, WV-OH Maintenance Plan under the 1997 Ozone Standard 

The original redesignation request and maintenance plan document was submitted to 

U.S. EPA on June 20, 2006. U.S. EPA approved this request on May 16, 2007 (72 FR 

27644). 

Ohio EPA is now requesting a revision to the maintenance plan to update mobile 

emission projections and conformity budgets based on emission rates generated from 

U.S. EPA’s latest mobile emissions model, the Motor Vehicle Emission Simulation 

(MOVES) 2010. In December 2009, MOVES replaced MOBILE6.2 as the U.S. EPA’s 

official emission factor model. The area is still attaining and maintaining the 1997 8-hour 

ozone standard and the point, area and non-road emissions have not changed 

significantly and did not need to be updated for this submittal. 

A redline/strike-out version of the original document follows this synopsis and identifies all 

changes that were made to the original approved request. In summary, revisions were 

made to the on-road (mobile) source emission estimates and budgets contained within 

the tables and text below. In addition, the discussion section regarding on-road modeling 

protocols was updated to identify the latest process applicable to the use of the newer 

MOVES model. Other minor changes were made to conform to current terminology, 

grammar, and formatting conventions. 

In addition to this document, additional changes were also made to the Appendices of the 

original submittal, as follows: 

• Appendix C: this appendix contains the detailed modeling protocol used to 

generate on-road mobile source emission estimates. The document contained 

within this revised submittal is an entirely new document compared to the original 

modeling protocol document submitted in 2006. Both the original and revised 

documents are available on Ohio EPA’s website under the “Appendix” link. 

• Appendix D: this appendix contains documents relevant to the public comment 

period and the public hearing. This will contain a revised public notice and revised 

hearing transcript. In some cases, if comments are received or testimony provided, 

it will also contain a revised response to comments document. Both the original 

and revised documents are available on Ohio EPA’s website under the “Appendix” 

link. 

These documents can all be found at: http://www.epa.ohio.gov/dapc/SIP/1997.aspx in the 

table under the heading “Redesignations and Maintenance Plans.” 
REQUEST FOR REDESIGNATION AND

MAINTENANCE PLAN FOR

OZONE ATTAINMENT 

IN THE OHIO PORTION OF THE 

WHEELING, WV-OH EIGHT-HOUR 

OZONE BASIC

NONATTAINMENT AREA 

Belmont County, Ohio

(Wheeling, WV-OH: Belmont County) 

Developed By: 

Ohio Environmental Protection Agency 

Division of Air Pollution Control in collaboration with 

West Virginia Department of Environmental 

Protection 

June 20, 2006

Revised December 2012
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 i 

TABLE OF CONTENTS 

Chapter One 

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

Background ................................................................................................................................... 1 

Geographical description .............................................................................................................. 2 

Status of air quality ....................................................................................................................... 2 

Chapter Two 

Requirements for redesignation .................................................................................................... 3 

Chapter Three 

Ozone monitoring .......................................................................................................................... 6 

Ambient data quality assured ........................................................................................................ 7 

Three complete years of data ....................................................................................................... 7 

Commitment to continue monitoring ............................................................................................. 9 

Chapter Four 

Emission Inventory ...................................................................................................................... 11 

Base Year Inventory ................................................................................................................... 11 

Emission Projections ................................................................................................................... 12 

Demonstration of Maintenance ................................................................................................... 17 

Permanent and Enforceable Emissions Reductions ................................................................... 22 

Provisions for Future Updates .................................................................................................... 23 

Chapter Five 

Control measures and regulations .............................................................................................. 24 

Implementation of Past SIP Revisions ........................................................................................ 24 

New Source Review Provisions ................................................................................................. 26 

Controls to remain in effect ......................................................................................................... 26 

Assurance of continued controls ................................................................................................. 26 

Chapter Six 

Contingency measures ............................................................................................................... 28 

Commitment to revise plan ......................................................................................................... 28 

Commitment for contingency measures ..................................................................................... 28 

Potential contingency measures ................................................................................................. 29 

List of VOC and NOx sources...................................................................................................... 30 

Chapter Seven 

Public participation ...................................................................................................................... 32 

Chapter Eight 

Conclusions ............................................................................................................................ 3233
 ii 

FIGURES 

Figure 1 Map of monitor locations for Wheeling, WV-OH: Belmont County Basic 

Nonattainment Area2002 – 2004..... ..................................................................... 6 

Figure 2 Map of monitor locations for Wheeling, WV-OH: Belmont County 2003 – 2005.....7 

TABLES 

Table 1 Monitoring Data for Wheeling, WV-OH: Belmont County 2002 – 2004 ................ 8 

Table 2 Monitoring Data for Wheeling, WV-OH: Belmont County 2003 - 2005 ............... 89

Table 3 Emission Estimations for On-road Mobile Sources for Belmont Co. Ohio ....... 1415

Table 4 Emission Estimations for On-road Mobile Sources for Ohio Co. WV .............. 1415

Table 5 Emission Estimations for On-road Mobile Sources for Marshall Co. WV ........ 1415

Table 6 Combined Emission Estimations for On-Road Sources ...................................... 16 

Table 7 Mobile Vehicle Emission Budget Belmont Co. .................................................... 16 

Table 8 VOC Emission Inventory Belmont Co. Ohio .................................................... 1618

Table 9 VOC Emission Inventory Marshall Co and Ohio Co. WV .................................... 18 

Table 10 Combined OH-Wheeling, WV: VOC Emission Inventory Totals .......................... 19 

Table 11 NOx Emission Inventory Belmont Co. Ohio ......................................................... 19 

Table 12 NOx Emission Inventory Marshall Co and Ohio Co. WV ..................................... 20 

Table 13 CombinedWheeling, WV: NOx Emission Inventory Totals ................................... 20 

Table 14 Projected Emission Estimates 2004-2018 Belmont Co. Ohio ............................. 21 

Table 15 Projected Emission Estimates 2004-2018 Marshall Co and Ohio Co. WV .......... 21 

Table 16 Combined Projected Emission Estimates 2004-2018 ........................................ 21 

Table 17 Combined Comparison of 2002 and 2004 On-road and EGU Totals .................. 23 

 

APPENDICES 

A Aerometric Information Retrieval System (AIRS) Data 

B Emission Inventories 

C Emissions Analysis Method 

D Public Participation Documentation 
 iii 

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 1 

REQUEST FOR REDESIGNATION AND

MAINTENANCE PLAN FOR OZONE ATTAINMENT 

IN THE OHIO PORTION OF THE 

WHEELING, WV-OH 

EIGHT-HOUR OZONE BASIC 

NONATTAINMENT AREA 

Wheeling, WV–OH: Belmont County 

CHAPTER ONE 

Introduction 

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

Standard (NAAQS) for ozone to develop State Implementation Plans (SIP’s) to 

expeditiously attain and maintain the standard. In 1997, the United States Environmental 

Protection Agency (U.S. EPA) revised the air quality standards for ozone replacing the 

1979 one-hour standard with an eight-hour ozone standard set at 0.08 parts per million 

(ppm). The standard was challenged legally and upheld by the U.S. Supreme Court in 

February of 2001. 

On April 15, 2004, U.S. EPA designated 134 nonattainment areas for the eight-hour ozone 

standard. Since that time, U.S. EPA has reclassified nine of the 134 original nonattainment 

areas to the next lower classification. Section 107(d)(3)(E) of the CAA allows states to 

request nonattainment areas be redesignated to attainment providing certain criteria are 

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

from nonattainment to attainment: 

i) A determination that the area has attained the eight-hour ozone standard.

ii) An approved State Implementation Plan (SIP) for the area under Section 

110(k).

iii) A determination that the improvement in air quality is due to permanent 

and enforceable reductions in emissions resulting from implementation of 

the SIP and other federal requirements.

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

v) A determination that all Section 110 and Part D requirements have been 

met. 

 

Background 

Belmont County, Ohio, Marshall and Ohio Counties in WV form the Wheeling-Belmont, WVOH interstate nonattainment area and constitute the Wheeling Metropolitan Statistical Area. 

 As part of the 1990 CAA Amendments re-evaluation, the Wheeling, WV-OH: Belmont 

County area was designated as Unclassifiable/Attainment for the one-hour ozone standard 

pursuant to the CAA and therefore, has not previously been subject to nonattainment area 

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 2 

rule-makings. As a result of the 2004 ozone designations, U.S. EPA designated Wheeling, 

WV-OH: Belmont County basic nonattainment and subject to the eight-hour ozone 

requirements, including development of a plan to reduce volatile organic compounds 

(VOCs) and oxides of nitrogen (NOx) emissions and a demonstration that the area will meet 

the federal eight-hour air quality standard for ozone by June 2009. 

This document is intended to support Ohio’s request that Wheeling, WV-OH: Belmont 

County area be redesignated from nonattainment to attainment for the eight-hour ozone 

standard. Monitoring data for the Wheeling, WV area, including Belmont County, OH, have 

recorded three (3) years of complete, quality-assured ambient air quality monitoring data 

for the years 2002 – 2004 demonstrating attainment of the eight-hour ozone standard. In 

addition, the three-year period 2003 – 2005 continues to demonstrate attainment of the 

eight-hour standard. 

 Geographical Description

Belmont County is located in eastern Ohio and contains the city of St. Clairsville. Belmont 

County is bordered by Harrison County to the north, Monroe to the south, Guernsey and 

Noble to the west and Ohio and Marshall Counties in West Virginia to the east. This area is 

shown in Figure 1. 

 Status of Air Quality 

Ozone monitoring data for the three (3) years, 2002 through 2004, demonstrates that the 

air quality has met the NAAQS for ozone in this basic nonattainment area. The most recent 

three-year period, 2003 through 2005, continues to demonstrate attainment of the 

standard. The NAAQS attainment, accompanied by decreases in emission levels 

discussed in Chapter four, supports a redesignation to attainment for Wheeling, WV-OH: 

Belmont County based on requirements in Section 107(d)(3)(E) of the CAA. 
 3 

CHAPTER TWO 

Requirements for Redesignation 

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

Processing Requests to Redesignate Areas to Attainment (redesignation guidance), issued 

September 4, 1992, to Regional Air Directors. This request for redesignation and 

maintenance plan is based on the redesignation guidance, supplemented with additional 

guidance received from staff of U.S. EPA Region V. 

Below is a summary of each redesignation criterion as it applies to Wheeling, WV-OH: 

Belmont County. 

i.) Attainment of the standard: 

 There are two components involved in making this demonstration. The first 

component relies on ambient air quality data. The data that are used to 

demonstrate attainment should be the product of ambient monitoring that is 

representative of the area of highest concentration. The data should be 

collected and quality-assured in accordance with 40 CFR 58 and recorded in 

the Aerometric Information Retrieval System (AIRS) in order for it to be 

available to the public for review. 

 The second component relies upon supplemental U.S. EPA-approved air 

quality modeling. The supplemental modeling is not required for ozone 

nonattainment areas seeking redesignation. Therefore, this ozone 

redesignation request for Wheeling, WV-OH: Belmont County does not 

include modeling data. However, in Appendix C the most recent modeling 

results showing future attainment and maintenance are provided. Chapter 

three discusses this requirement in more detail and provides the attainment 

demonstration. 

ii.) SIP approval: 

 The SIP for the area must be fully approved under Section 110(k) and must 

satisfy all requirements that apply to the area. Ohio’s SIP was approved on 

May 9, 1994 (59FR23799) March 23, 1995 (60FR15235) and includes 

Wheeling, WV-OH: Belmont County. Chapter five discusses this 

requirement in more detail and provides the attainment demonstration. 

iii.) Permanent and enforceable improvement in air quality: 

 The state must be able to reasonably attribute the improvement in air quality 

to emission reductions which are permanent and enforceable. The state 
 4 

should estimate the percent reduction achieved from federal measures as 

well as control measures that have been adopted and implemented by the 

state. 

 Wheeling, WV-OH: Belmont County was not designated nonattainment for 

ozone as part of the 1990 CAA Amendments re-evaluation. As a result, Ohio 

has not adopted or implemented control measures beyond the federal 

measures, the initial 1979 statewide rules and those 1994 and 1995 rules 

which applied to “rural” attainment areas. Chapters four and five discuss this 

requirement in more detail and provide the attainment demonstration. 

iv.) Section 110 and Part D requirements: 

 For purposes of redesignation, a state must meet all requirements of Section 

110 and part D that were applicable prior to submittal of the complete 

redesignation request. 

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

designated nonattainment based on a violation of the NAAQS. 

 i.) Section 172(c) requirements 

 This section contains general requirements for nonattainment plans. 

The requirements for reasonable further progress, identification of 

certain emissions increases, and other measures needed for 

attainment will not apply for redesignations because they only have 

meaning for areas not attaining the standard. The requirements for an 

emission inventory will be satisfied by the inventory requirements of 

the maintenance plan. 

 ii.) Conformity 

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

consistent with section 176(c)(4) conformity requirements. The 

redesignation request should include conformity procedures, if the 

state already has these procedures in place. If a state does not have 

conformity procedures in place at the time that it submits a 

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

conformity regulation upon issuance, as applicable. Chapter five 

discusses this requirement in more detail and provides the attainment 

demonstration. 

v.) Maintenance plans. 

 Section 107(d)(3)(E) stipulates that for an area to be redesignated, U.S. EPA 

must fully approve a maintenance plan which meets the requirements of 

Section 175(A). The maintenance plan will constitute a SIP revision and 

must provide for maintenance of the relevant NAAQS in the area for at least 

10 years after redesignation. Section 175(A) further states that the plan shall 
 5 

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

such maintenance. 

In addition, the maintenance plan shall contain such contingency measures 

as the Administrator deems necessary to ensure prompt correction of any 

violation of the NAAQS. At a minimum, the contingency measures must 

include a requirement that the state will implement all measures contained in 

the nonattainment SIP prior to redesignation. 

States seeking redesignation of a nonattainment area should consider the 

following provisions: 

 a.) attainment inventory; 

 b.) maintenance demonstration; 

 c.) monitoring network; 

 d.) verification of continued attainment; and 

 e.) contingency plan. 

 

 Chapter six discusses this requirement in more detail and provides the 

attainment demonstration. 
 6 

CHAPTER THREE 

OZONE MONITORING

CAA Section107 (d)(3)(E)(i) 

Requirement 1 of 4: 

A demonstration that the NAAQS for ozone, as published in 40 CFR 50.4, has been 

attained. Ozone monitoring data must show that violations of the ambient standard are no 

longer occurring. 

Background: 

 There are no monitors measuring ozone concentrations in Belmont County. 

As shown in Figure 1 the two monitors used for measuring ozone 

concentrations for Belmont County in 2002 thru 2004 are located in Ohio 

County in West Virginia. The monitors are operated by the West Virginia 

Department of Environmental Protection (DEP), Division of Air Quality (DAQ), 

Northern Panhandle Regional Office. Figure 2 shows the location of the 

monitor locations for 2003 thru 2005. See Requirement 3 of 4 Demonstration 

section in this chapter for an explanation of the monitor relocation. 

Demonstration: 

Figure 1 Map of monitor locations for Wheeling, WV-OH: Belmont County (2002 – 2004)
 7 

 Figure 2 Map of monitor locations for Wheeling, WV-OH: Belmont 

 County (2003 – 2005)

Figure 2 Map of monitor locations for Wheeling, WV-OH: Belmont 

 County (2003 – 2005)

Requirement 2 of 4: 

Ambient monitoring data quality assured in accordance with 40 CFR 58.10, recorded in the 

U.S. EPA air quality system (AQS) database, and available for public view. 

Demonstration: 

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 8 

WV has quality assured all data shown in Appendix A in accordance with 40 

CFR 58.10 and all other federal requirements. WV has recorded the data in 

the AQS database and therefore data are available to the public. 

Requirement 3 of 4: 

A showing that the three-year average of the fourth highest values, based on data from all 

monitoring sites in the area or its affected downwind environs, are below 85 parts per billion 

(ppb). This showing must rely on three (3) complete, consecutive calendar years of quality 

assured data.

Background: 

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

Handling Conventions for the eight-hour Ozone National Ambient Air Quality 

Standard (NAAQS)," U.S. EPA-454/R-98-017, December 1998. 

Three (3) complete years of ozone monitoring data are required to 

demonstrate attainment at a monitoring site. The eight-hour primary and 

secondary ozone ambient air quality standards are met at an ambient air 

quality monitoring site when the three-year average of the annual fourthhighest daily maximum eight-hour average ozone concentration is less than 

or equal to 0.08 ppm. When this occurs, the site is said to be in attainment. 

Three (3) significant digits must be carried in the computations. Because the 

third decimal digit, in ppm, is rounded, 0.084 ppm is the largest concentration 

that is less than or equal to 0.08 ppm. Therefore, for the purposes of this 

request, the eight-hour standard is considered to be 0.085 ppm. Values 

below 0.085 ppm meet the standard, values equal to or greater than 0.085 

ppm exceed the standard. These data handling procedures are applied on 

an individual basis at each monitor in the area. An area is in compliance with 

the eight-hour ozone NAAQS if, and only if, every monitoring site in the area 

meets the NAAQS. An individual site's three (3) year average of the annual 

fourth highest daily maximum eight-hour average ozone concentration is also 

called the site's design value. Table 1 shows the monitoring data for 2002 – 

2004 and Table 2 shows the monitoring data for 2003-2005 at the 

nonattainment area sites and was retrieved from the U.S. EPA AQS. 

Demonstration: 

 A listing of the four (4) highest readings from 2002 through 2004 is shown in 

Table 1 and readings from 2003-2005 are shown in Table 2. These readings 

were retrieved from the U.S. EPA air quality system (AQS.) 

Table 1: Monitoring Data for Wheeling, WV-OH: Belmont County 2002 – 

 2004 
 9 

Data source: U.S. EPA Air Quality System (AQS). 

 http://www.epa.gov/ttn/airs/airsaqs/index.htm

 

1st 2nd 3rd 4th 2002-2004 

SITE ID COUNTY ADDRESS YEAR %OBS 8-HR 8-HR 8-HR 8-HR AVERAGE 

54-069-0007 OHIO (WV) NORTHERN PANH 2002 100 .099 .097 .097 .097

54-069-0007 OHIO (WV) NORTHERN PANH 2003 99 .111 .097 .085 .076

54-069-0009 OHIO (WV) WHEELING EPA 2004 100 .076 .072 .067 .063 

0.78 ppm 

Table 2: Monitoring Data for Wheeling, WV-OH: Belmont County 2003 – 

 2005 

Data source: U.S. EPA Air Quality System (AQS). 

 http://www.epa.gov/ttn/airs/airsaqs/index.htm

1st 2nd 3rd 4th 2003-2005 

SITE ID COUNTY ADDRESS YEAR %OBS 8-HR 8-HR 8-HR 8-HR AVERAGE 

54-069-0007 OHIO (WV) NORTHERN PANH 2003 99 .111 .097 .085 .076

54-069-0009 OHIO (WV) WHEELING EPA 2004 100 .076 .072 .067 .063 

54-069-0010 OHIO (WV) WARWOOD WATER 2005 100 .097 .097 .091 .089

0.76 ppm 

Seasonal ozone monitoring at Wheeling, WV site number 54-069-0007 

began in 1982 and continued until the end of the 2003 ozone season due to 

the relocation of the WV Division of Air Quality (DAQ) Northern Panhandle 

Regional Office. While a long term replacement for the Wheeling ozone 

monitoring site was being established, an interim site (number 54-069-0009) 

was established in Wheeling for the 2004 ozone monitoring season. This 

interim site was located approximately four miles south of the original 

(number 54-069-0007.) A new Wheeling monitoring site, number 54-069-

0010 was installed in late 2004. This monitor is located approximately three 

tenths of a mile south of the original site (number 54-069-0007) and was 

operational for the 2005 ozone season. 

 Data from the interim site would need to have shown a 4th highest eight-hour 

ozone average of 0.082 ppm in 2004 for the three year average ozone 

concentration to violate the NAAQS for the period 2002-2004. An 

examination of the data from the other ozone monitoring sites also 

demonstrates that none of these locations exceeded an ozone average of 

0.082 ppm. 

Formatted Table

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 10 

The area's design value has trended downward as emissions have declined 

due to such factors as cleaner automobiles and fuels both regionally and 

locally. U.S. EPA’s rule to control nitrogen oxides from specific source 

categories (40 CFR Parts 51, 72, 75 and 96, published on October 17, 1998 

and referred to as the NOx SIP Call) has significantly reduced emissions from 

large electric generating units (EGUs), industrial boilers, and cement kilns. 

Ohio's NOx Budget Trading Program rule was approved on May 25, 2004 

[Ohio Administrative Code (OAC) Chapter 3745-14]. It is expected that this 

downward trend will continue as the above programs continue and some 

form of the U.S. EPA Clean Air Interstate Rule (CAIR) is implemented. 

Requirement 4 of 4: 

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

monitoring network to verify the maintenance of the attainment status. 

Demonstration: 

 WV commits to continue monitoring ozone levels at the sites indicated in 

Figure 2. WV will consult with U.S. EPA Region III staff prior to making 

changes to the existing monitoring network, should changes become 

necessary in the future. WV will continue to quality assure the monitoring 

data to meet all federal requirements. WV will enter all data into AQS on a 

timely basis in accordance with federal guidelines. 

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+ 5" + 5.5"
 11 

CHAPTER FOUR 

EMISSION INVENTORY

CAA Section107 (d)(3)(E)(iii) 

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

ozone precursor emissions (VOC and NOx) representative of the year when the area 

achieves attainment of the ozone air quality standard. Ohio also must demonstrate that the 

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

attainment was achieved is based on permanent and enforceable emission reductions. 

Other emissions inventory related requirements include a projection of the emission 

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

projected level of emissions is sufficient to maintain the ozone standard; and a commitment 

to provide future updates of the inventory to enable tracking of emission levels during the 

10 year maintenance period. 

Requirement 1 of 5: 

A comprehensive emission inventory of the precursors of ozone completed for the base 

year. 

Background: 

The point source data are taken from Ohio's annual emissions reporting 

program. The 2002 periodic inventory has been identified as the preferred 

data base for SIP development and does coincide with nonattainment air 

quality in Wheeling, WV-OH: Belmont County. 
 12 

As part of the NOx SIP Call, many states, including Ohio were required to 

adopt into their rules a budget for all large EGUs. Ohio’s budget is adopted 

at OAC Chapter 3745-14. The budget represents a statewide cap on NOx

emissions. These emissions, capped by the state rule, should remain at or 

near this level through the maintenance period covered by this request. 

Periodic inventories, which include emissions from all sectors - mobile, area, 

non-road, and point sources - are prepared every three (3) years. 

Demonstration: 

While ozone and its precursors are transported into this region from outside 

areas, this information does provide some indication of the impact from Ohio 

sources near the nonattainment area. The emissions are decreasing 

substantially in response to regional and national programs affecting many 

EGUs such as the Acid Rain program and the NOx SIP Call. Other sectors of 

the inventory also impact ozone formation, but large regional sources such 

as EGUs have a substantial impact on the formation of ozone. 

Requirement 2 of 5: 

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

Background: 

Ohio EPA prepared a comprehensive inventory for Belmont County, including 

area, mobile, and point sources for precursors of ozone (VOCs and NOx) for 

base year 2002. The information below describes the procedures Ohio EPA 

used to generate the 2002 base inventories. These inventories were 

provided to Lake Michigan Air Directors Consortium (LADCO) and have been 

processed to develop summer day emissions for use in the air quality 

analyses. These processed modeling inventories have been identified as the 

correct iteration of the inventory for use in the redesignation. In this 

document, references to LADCO include the Midwest Regional Planning 

Organization. 

• Area sources were taken from the Ohio 2002 periodic inventory 

submitted to U.S. EPA. These projections were made from the U.S. 

Department of Commerce Bureau of Economic Analysis (BEA) growth 

factors, with some updated local information. 

• Mobile source emissions were calculated from MOBILE6.2MOVES 

2010 produced emission factors. 
 13 

• Point source information was compiled from Ohio EPA’s 2002 annual 

emissions inventory database and the 2002 U.S. EPA Air Markets 

acid rain database1

. 

• Biogenic emissions are not included in these summaries. 

• Non-road emissions were generated using U.S. EPA’s National Mobile 

Inventory Model (NMIM) 2002 application. To address concerns 

about the accuracy of some of the categories in U.S. EPA’s non-road 

emissions model, LADCO contracted with two (2) companies to 

review the base data and make recommendations. One of the 

contractors also estimated emissions for three (3) non-road categories 

not included in U.S. EPA’s non-road model. Emissions were estimated 

for aircraft, commercial marine vessels and railroads. Recreational 

motorboat population and spatial surrogates (used to assign 

emissions to each county) were significantly updated. The 

populations for the construction equipment category were reviewed 

and updated based upon surveys completed in the Midwest and the 

temporal allocation for agricultural sources also was updated. 

Demonstration: 

On-Road Emission Estimations 

In coordination with the Belmont, Ohio, Marshall Regional Council 

Metropolitan Planning Organization (Bel-O-Mar) and the West Virginia 

Department of Transportation (WVDOT), the Ohio Department of 

Transportation (Ohio DOTODOT) utilizes a regional travel demand forecast 

model to simulate traffic in the area and to forecast traffic flows for given 

growth expectations. The model is primarily used as a long range planning 

tool to evaluate the transportation system including determination of locations 

where additional travel capacity may be needed and to determine the 

infrastructure requirements necessary to meet that need. It is also used as a 

tool for air quality purposes to estimate the total emissions of pollution 

caused by vehicles in the area. The travel demand forecasting model is used 

to predict the total daily vehicle miles traveled (VMT) and an EPA computer 

program called MOBILE6.2MOVES2010 is used to calculate emissions per 

mile. The product of these is the total amount of pollution emitted by the onroad vehicles for the particular analyzed area. 

Overview 

Broadly described, MOBILE6.2MOVES2010 is used to generate “emission 

 

1 http://www.epa.gov/airmarkets/acidrain 

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 14 

factors”, which are the average emissions per mile (grams/mile) for ozone 

precursors, NOx and VOC. The MOBILE6.2MOVES2010 model includes a 

number of variables that affect the emission factors. These variables have 

national default values, some of which require modification to reasonably 

reflect local conditions. Some of these variables are discussed here. The 

vehicle fleet (vehicles on the road) age and the vehicle type have a major 

effect on the emission factors. The vehicle source types are traveling on 

facilityroad types (MOBILE6.2 facilityMOVES2010 road types are Freeway, 

Arterial, Local and Ramp) and the vehicle Rural Restricted Access, Rural 

Unrestricted Access, Urban Restricted Access, and Urban Unrestricted 

Access). The vehicle speeds also affect the emission factor values. 

Meteorological conditions such as air temperature and humidity has a 

significant affecteffect on emission factors. Emission factors produced by 

MOBILE6.2MOVES2010 can also include the effect of emission reduction 

strategies such as vehicle inspection and maintenance programs, regulation 

of fuels, etc. These MOBILE6.2MOVES2010 inputs are estimated using the 

best available data. 

These inputs are reviewed and agreed to by EPA and transportation 

agencies in a formal interagency consultation process. Emission factors are 

multiplied by VMT from the travel demand model to estimate the total vehicle 

emissions. 

There are a number of ways emission factors from MOBILE6.2 can be used 

with the travel demand model information. One of the simplest methods is to 

input extensive vehicle fleet, area-specific speed and facility type information 

MOBILE6.2 to generate a single emission factor that represents the average 

for all vehicles and facility types in the modeled area. This only requires 

multiplying this emission factor by the total VMT of the analyzed area to get 

the total emissions for the area. Another method is to create multidimensional emission factor “look-up” tables that describe the emission 

factors by speed, temperature, and facility type. This requires more 

extensive processing, but the resulting total emissions of this method are 

more sensitive to even minor changes in the roadway system. Tables of 

emission factors are created using MOBILE6.2 for each facility type, 

temperature, and speed given the vehicle fleet on that facility. Then, the 

travel model provides information on each segment of road (or “link”) 

regarding speed and facility type which is then “looked-up” in the appropriate 

emission factor table. It should be noted that speed is estimated as a post 

process to the travel demand model. Speeds are not taken directly from the 

travel demand model. The post process for emissions analysis by Ohio DOT 

is by hour of day. This emission factor is multiplied by the link’s trafficvolume and length or VMT to get the emissions from that link for that hour. 

There are other methods as well, each with its advantages and 

disadvantages. The Wheeling, WV-OH: Belmont County analysis uses the 

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latter more complex method, a table of emission factors. 

It should be noted that each year analyzed will have different emission 

factors, volumes, speeds and roadway networks. 

Some of the assumptions built into MOBILE6.2 are: older vehicles have 

much higher emission factors than newer vehicles, diesel vehicles have 

much higher NOx emission factors and lower VOC emission factors than 

gasoline vehicles, and higher average speeds have lower emission factors 

except for diesel vehicles which have higher NOx at higher speeds. 

MOBILE6.2 input and output files are provided in Appendix C. 

The emission factors from MOVES2010 can be used with the travel demand 

model information by combining the disaggregate emission rates with VMT, 

and source type population for each road type, source type and hour of day, 

and then sum them up to get the total emissions for the area. 

The Bel-O-Mar analysis method, developed by ODOT, is to aggregate the 

emission rates by two source types (cars & trucks), then applying VMT and 

source type population, thereby reducing the intensive processes. In the first 

step emission factors are broadly classified into total vehicles, cars and 

trucks by pollutant, by average speed, road type and hour of day. Then the 

hourly link volumes generated from travel demand model are combined with 

emission factors for each network link for each hour. The on-road vehicle 

emissions for the area are the sum of all individual link-hour emissions. 

Vehicle-based emissions are obtained by the combination of corresponding 

emission factors and source type population. Intrazonal emissions are 

computed using a separate method to account for those trips that use local 

roads to travel within a zone. Intrazonal VMT is combined with corresponding 

emission factors to get intrazonal emissions. Total emissions are sum of onroad vehicle emissions, vehicle-based emissions and intrazonal emissions. 

Automated programs, using FORTRAN and CUBE scripting, were developed 

by ODOT to generate total emissions. The process uses data on daily and 

directional traffic distributions as well as more up to date volume/delay 

functions from the 2000 Highway Capacity Manual (HCM). This process also 

handles the newer model network formats and MOVES generated emission 

factors 

Best Available Data 

Most current vehicle age distribution data, temperature data, and fuel 

properties data, and source type distribution data provided by ODOT’s ATRs 

and WIMs, NOAA, ODPS, and Ohio EPA waswere used by the Ohio 

DOTODOT for generating emission factors. Likewise, the most current 

transportation planning data and count data available was used byfrom BelO-Mar and Ohio DOT. Details about each data set and how it was used is 

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documented in Ohio DOT’s “Bel-O-Mar 8-Hour Ozone Air Quality Conformity 

Analysis Technical Memo” dated 5/25/2006most current ODOT count data 

were used for the emissions estimates. 

Analysis Years 

Analysis years for this re-designation request include 2002, 2004, 2009, and 

2018 to meet the requirements specified by the CAA and EPA. The travel 

demand model presents the transportation system conditions for each of 

these years. Model runs for each future analysis year contain the road 

network Bel-O-Mar and ODOT expects to exist at the beginning of that year 

with corresponding socioeconomic forecasts for that year. 

Local Road VMT 

Most local roads such as subdivision streets are not explicitly modeled in a 

travel demand model. These local roads are represented as fictitious 

roadways called centroid connectors. Local road VMT is included in the Ohio 

DOTODOT post process by including the traffic loaded on centroid 

connectors. In addition, some local road traffic is captured as intra-zonal 

trips which travel demand models usually do not assign to roadway 

segments. The Ohio DotODot post process includes these trips as local road 

VMT. 

Emission Estimations 

Tables 3 through 5 contain the results of the emissions analysis for the 

appropriate years. 

Table 3 Emission Estimations for On-Road Mobile Sources for 

 Belmont County, Ohio 

 Data source: On-road only, Ohio DOT Modeling and Forecasting Section.

Belmont County - Ohio 2002 2004 2009 2018

VMT (miles/day) 2,255,411675,185 2,269,517658,945 2,301,056720,328 2,383,528822,495

VOC (tons/day) 4.225.39 3.525.04 2.263.76 1.3272

NOx (tons/day) 7.3614.99 13.986.29 4.0810.64 1.664.14

Table 4 Emission Estimations for On-Road Mobile Sources for Ohio 

County, WV 

Data source: On-road only, Ohio DOT Modeling and Forecasting Section.

Ohio County, WV 2002 2004 2009 2018

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VMT (miles/day) 1,110,762291,256 1,128,656317,716 1,508,290743,104 1,486,898722,611

VOC (tons/day) 2.1811 1.8496 1.5750 0.8766

NOx (tons/day) 3.856.65 3.325.63 2.834.42 1.0946

Table 5 Emission Estimations for On-Road Mobile Sources for 

 Marshall County, WV 

Data source: On-road only, Ohio DOT Modeling and Forecasting Section.

Marshall County, WV 2002 2004 2009 2018 

VMT (miles/day) 676,168845,952 675,024774,247 706,831819,606 736,198852,369

VOC (tons/day) 1.1740 0.971.24 0.6586 0.3739

NOx (tons/day) 1.602.99 2.481.35 0.921.86 0.3869

Table 6 Combined VOC and NOx Emission Estimations for On-Road 

Mobile Sources for Belmont County, OH, Marshall and Ohio 

County, WV 

Data source: On-road only, Ohio DOT Modeling and Forecasting Section.

County VOC 2018

Belmont County, OH VOC 1.3272

Marshall County, WV VOC 0.3739

Ohio County, WV VOC 0.8766

TOTAL 2.5677

NOx

Belmont County, OH NOx 1.664.14

Marshall County, WV NOx 0.3869

Ohio County, WV NOx 1.0946

TOTAL 6.293.13

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Motor Vehicle Emission Budget 

Table 7 contains the motor vehicle emissions budget for Belmont County, 

Ohio. 

Table 7 Mobile Vehicle Emission Budget for Belmont County, OH 

Data source: Ohio DOT Modeling and Forecasting Section.

2009 2018

 VOC (tons/day 2.604.70 1.522.15

 NOx (tons/day) 4.6913.30 1.915.18

This budget includes the emission estimates calculated for 2018. The 

emission estimates are derived from the QRS travel demand model and 

MOBILE6.2 asMOVES 2010as described above under the expected 

Belmont-Ohio Marshall Regional Council Metropolitan Planning Organization 

(Bel-O-Mar) 2025 Long Range Plan. The mobile source budget for Belmont 

County includes 1.522.15 tons/day for VOC and 1.915.18 tons/day for NOx. 

These correspond to a 1525 percent increase from the 2018 on-road 

emissions for both VOC and NOx. Appendix C contains data tables and 

graphs of these emissions. 

All methodologies, latest planning assumptions and the safety margins were 

determined through the interagency consultation process described in the 

Transportation Conformity Memorandum of Understanding (MOU) for Bel-OMar. 

Requirement 3 of 5: 

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

standard. 

Background: 

In consultation with U.S. EPA, Ohio EPA selected the year 2018 as the 

maintenance year for this redesignation request. This document contains 

projected emissions inventories for 2009 and 2018. Ohio DOT performed 

emission projections for Wheeling, WV-OH: Belmont County using the 

following approaches. 

• Mobile source emission projections are based on the U.S. EPA 

MOBILE6.2MOVES 2010 model. The analysis is described in more 

detail in Appendix C. All projections were made in accordance with 

“Procedures for Preparing Emissions Projections” U.S. EPA-45/4-91-

019. 

• Emissions inventories are required to be projected to future dates to 

assess the influence growth and future controls will have. LADCO 

developed growth and control files for point, area, and non-road 

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categories. These files were used to develop the future year 

emissions estimates used in this document. This was done so the 

inventories used for redesignation are consistent with modeling 

performed in the future. 

The detailed inventory information for Belmont County for 2004, 2009 and 

2018 is in Appendix B. Emission trends are an important gauge for continued 

compliance with the ozone standard. Therefore, Ohio EPA performed an 

initial comparison of the inventories for the base year and maintenance 

years. Mobile source emission inventories are described in Appendix B. In 

addition to the LADCO estimates, point source emissions were projected 

based upon the statewide EGU NOx budgets from the Ohio NOx rule. 

Emission Inventories for Marshall and Ohio Counties in WV used for this 

request were developed by DEP staff with the support of the contractors for 

the Visibility Improvement State and Tribal Association of the Southeast 

(VISTAS), a federally recognized regional planning organization. 

The following tables include sectors Electrical Generating Unit (EGU-Point), 

Non-Electrical Generating Unit (Non-EGU), Non-road Mobile (Non-road), 

Other Area (Other), Marine, Aircraft, Rail (MAR), On-road Mobile (On-road). 

Please note that WV non-road sector includes MAR. 

Demonstration: 

Table 8 Belmont County, OH VOC Emission Inventory Totals for Base 

 Year 2002, Estimated 2004 and Projected 2009 and 2018 (tons 

 per day) 

Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air 

 Directors Consortium (LADCO) Web site:

http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm. 

Data source: On-road only, Ohio DOT Modeling and Forecasting Section 

Sector 2002 

Base 

2004 

Attainment 

2009 

Interim

2018 

Maintenance

Safety 

Margin

EGU Point 0.19 0.17 0.12 0.17 

Non-EGU 0.03 0.03 0.03 0.04 

Non-road 0.94 0.88 0.76 0.56 

Other 4.10 4.03 3.85 3.86 

MAR 0.05 0.05 0.05 0.05 

On-road 4.225.39 3.525.04 1.522.15* 

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2.604.70* 

TOTAL 9.5310.70 8.6810.20 7.419.51 6.2083 3.372.48

 * includes 1525 percent increase to the mobile source budget 

Table 9 Combined Marshall and Ohio County, WV VOC Emission 

 Inventory Totals for Base Year 2002, Estimated 2004 and 

 Projected 2009 and 2018 (tons per day) 

Data source: WV emission inventory, Visibility Improvement State and Tribal Association of the 

 Southeast (VISTAS) http://www.vistas-sesarm.org/. 

Data source: On-road only, Ohio DOT Modeling and Forecasting Section

Sector 2002 

Base 

2004 

Attainment

2009 

Interim

2018 

Maintenance

Safety 

Margin

EGU Point 0.550 0.550 0.770 0.770

Non-EGU 2.550 2.550 2.110 2.660

Non-road (includes MAR) 2.330 2.330 2.110 1.880

Other (Area) 14.880 15.440 7.330 8.440

On-road Marshall 1.17 0.97 0.65 0.37 

On-road Ohio 2.1811 1.8496 1.5750 0.8766

TOTAL 23.4561 23.5190 14.4256 14.7455 8.779.35

Table 10 Wheeling, WV-OH: Belmont County: VOC Emission 

Inventory Totals for Base Year 2002, Estimated 2004 and 

Projected 2009 and 2018 (tons per day) 

Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air 

 Directors Consortium (LADCO) Web site: 

http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm. 

 Data source: WV emission inventory, Visibility Improvement State and Tribal Association of the 

 Southeast (VISTAS) http://www.vistas-sesarm.org/. 

Data source: On-road only, Ohio DOT Modeling and Forecasting Section. 

2002 Base 2004 

Attainment

2009 

Interim

2018

Maintenance

Safety 

Margin 

Maintenance 

Belmont Co. Ohio 

Total 

9.5310.70 8.6810.20 7.419.51 6.2083

Marshall and Ohio 23.4561 23.5190 14.4256 14.7455

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County WV Total

County WV Total 

COMBINED VOC 

TOTAL 

32.9834.31 32.1934.10 21.8324.07 20.9421.38 11.2512.72

Table 11 Belmont County NOx Emission Inventory Totals for Base Year 

 2002, Estimated 2004 and Projected 2009 and 2018 (tons per 

 day) 

Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air 

 Directors Consortium (LADCO) Web site: 

http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm. 

Data source: On-road only, Ohio DOT Modeling and Forecasting Section

Sector 2002 

Base 

2004 

Attainment 

2009 

Interim

2018 

Maintenance

Safety 

Margin

EGU Point 31.67 28.61 20.96 18.85 

Non-EGU 0.08 0.08 0.08 0.08 

Non-road 1.43 1.35 1.16 0.63 

Other 0.31 0.29 0.36 0.38 

MAR 1.61 1.54 1.38 1.28 

On-road 

7.3614.9

9

 6.2913.98 

4.6913.30

* 1.915.18* 

TOTAL 42.465

0.09

38.1645.85 28.6337.

24 23.1326.40 15.0319.46

 * includes 1525 percent increase to the mobile source budget 

Table12 Combined Marshall and Ohio County, WV NOx Emission 

 Inventory Totals for Base Year 2002, Estimated 2004 and 

 Projected 2009 and 2018 (tons per day) 

Data source: WV emission inventory, Visibility Improvement State and Tribal Association of the 

 Southeast (VISTAS) http://www.vistas-sesarm.org/. 

Data source: On-road only, Ohio DOT Modeling and Forecasting Section

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Sector 2002 

Base 

2004 

Attainment

2009 

Interim

2018 

Maintenance

Safety 

Margin

EGU Point 133.50 73.20 51.1 14.9 

Non-EGU 18.70 12.6 10.6 11.3 

Non-road (includes MAR) 5.60 7.3 5.2 4.6 

Other (Area) 3.40 3.4 1.8 2.0 

On-road Marshall 1.60 1.35 0.92 0.38 

On-road Ohio 3.856.6

5

3.325.63 2.834.42 1.0946

TOTAL 166.65

170.84

101.47104.

61

72.457

4.98

34.2795 67.206

9.66

Table 13 Wheeling, WV-OH: Belmont County: NOx Emission 

Inventory Totals for Base Year 2002, Estimated 2004 and 

 Projected 2009 and 2018 (tons per day) 

Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air 

 Directors Consortium (LADCO) Web site:

http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm. 

Data source: WV emission inventory, Visibility Improvement State and Tribal Association of the 

 Southeast (VISTAS) http://www.vistas-sesarm.org/. 

Data source: On-road only, Ohio DOT Modeling and Forecasting Section 

2002 Base 2004 

Attainment 2009 Interim 

2018

Maintenance

Safety 

Margin 

Belmont Co. 

Ohio Total 

42.4650.09 38.1645.85

28.6337.24 23.1326.40

Ohio and 

Marshall 

County WV 

Total 

166.65170.84 101.47104.61 72.4574.98 34.2795

COMBINED NOx

TOTAL 

209.11220.93 139.63150.46

101.08112.22 57.4061.35 82.2389.12

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Table 14 Belmont County, OH Comparison of 2004 attainment year and 

2018 projected emission estimates (tons per day, summer) 

 Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air 

 Directors Consortium (LADCO) Web site:

http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm. 

 Data source: On-road only, Ohio DOT Modeling and Forecasting Section.

2004 2018 Projected Decrease

VOC 8.6810.20 6.2083 2.483.37

NOx 38.1645.85 23.1326.40 15.0319.46

Table 15 Marshall and Ohio County, WV Combined Comparison of 2004 

attainment year and 2018 projected emission estimates (tons 

per day, summer) 

Data source: WV emission inventory, Visibility Improvement State and Tribal Association of the 

 Southeast (VISTAS) http://www.vistas-sesarm.org/. 

Data source: On-road only, Ohio DOT Modeling and Forecasting Section.

2004 2018 Projected Decrease

VOC 23.5190 14.7455 8.779.35

NOx 101.47104.61 34.2795 67.2069.66

Table 16 Wheeling, WV-OH: Belmont County Combined Comparison of 

2004 attainment year and 2018 projected emission estimates 

(tons per day, summer) 

 Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air 

 Directors Consortium (LADCO) Web site:

http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm. 

Data source: WV emission inventory, Visibility Improvement State and Tribal Association of the 

 Southeast (VISTAS) http://www.vistas-sesarm.org/. 

Data source: On-road only, Ohio DOT Modeling and Forecasting Section

2004 2018 Projected 

Decrease

Combined VOC Total 32.1934.

10

20.9421.

38 11.2512.72

Combined NOx Total 139.631

50.46

57.4061.

35 82.2389.12

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VOC emissions in the nonattainment area are projected to decrease by 

11.4512.72 tons. Area source emissions and, to a lesser extent, point 

sources, show an increase due to expectations that the population will grow 

in this area. However, cleaner vehicles and fuels are expected to be in place 

in 2009 and 2018 and result in an overall drop in VOC emissions. 

NOx emissions in the nonattainment area are projected to decrease by 

128.2489.12 tons. Decreases from U.S. EPA rules covering Tier 2 Motor 

Vehicle Emissions Standards and Gasoline Sulfur Control Requirements2, 

Highway Heavy-Duty Engine Rule3

 and Non-road Diesel Engine Rule4 also 

are factored into the changes. Further, due to implementation of the NOx SIP 

Call across the eastern United States, NOx and ozone levels entering this 

area also will be decreased. 

Requirement 4 of 5: 

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

attainment was achieved is based on permanent and enforceable emission reductions and 

not on temporary adverse economic conditions or unusually favorable meteorology. 

Background: 

Ambient air quality data from all monitoring sites indicate that air quality met 

the NAAQS for ozone in 2004. U.S. EPA’s redesignation guidance (p 9) 

states, “A state may generally demonstrate maintenance of the NAAQS by 

either showing that future emissions of a pollutant or its precursors will not 

exceed the level of the attainment inventory, or by modeling to show that the 

future mix of sources and emissions rates will not cause a violation of the 

NAAQS.” 

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

emissions information once every three (3) years or annually if VOC potential 

to emit is greater than 250 tons or NOx potential to emit is greater than 2500 

tons, in accordance with U.S. EPA’s Consolidated Emissions Reporting Rule 

(CERR). Ohio EPA prepares a new periodic inventory for all ozone precursor 

emission sectors every three (3) years. These ozone precursor inventories 

will be prepared for 2005, 2008, and 2011 as necessary to comply with the 

inventory reporting requirements established in the CFR. Emissions 

information will be compared to the 2002 base year and the 2018 projected 

maintenance year inventories to assess emission trends, as necessary, to 

assure continued compliance with the ozone standard. 

 

2 http://www.epa.gov/fedrgstr/EPA-AIR/2000/February/Day-10/a19a.htm 3 http://www.epa.gov/fedrgstr/EPA-AIR/1997/October/Day-21/a27494.htm 4 http://www.epa.gov/fedrgstr/EPA-AIR/1998/October/Day-23/a24836.htm 
 25 

Demonstration: 

Permanent and enforceable reductions of VOCs and NOx have contributed to 

the attainment of the eight-hour ozone standard. Permittable emission 

reductions between 2002 and 2004 were due to the application of tighter 

federal standards on new vehicles. Also, Title IV of the CAA and the NOx

SIP Call required the reduction of oxides of nitrogen from utility sources. 

Table 17 Wheeling, WV-OH: Belmont County Combined Comparison of 

2002 base year and 2004 attainment year on-road and EGU 

reductions 

Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air 

 Directors Consortium (LADCO) Web site:

http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm. 

Data source: WV emission inventory, Visibility Improvement State and Tribal Association of the 

 Southeast (VISTAS) http://www.vistas-sesarm.org/. 

Data source: On-road only, Ohio DOT Modeling and Forecasting Section.

2002 2004 Reduction

On-road VOC 7.588.90 6.338.24 1.250.66

On-road NOx 12.8124.63 10.9622.09 1.852.54

EGU NOx 165.17 101.81 63.36 

Requirement 5 of 5: 

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

levels including an annual emission statement from major sources. 

Demonstration: 

As required by Section 175A(b) of the CAA, Ohio commits to submit to the 

Administrator, eight (8) years after redesignation, an additional revision of 

this SIP. The revision will contain Ohio's plan for maintaining the national 

primary ozone air quality standard for 10 years beyond the first 10 year 

period after redesignation. 

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 26 

CHAPTER FIVE 

CONTROL MEASURES AND REGULATIONS

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

Requirement 1 of 4:

A U.S. EPA approved SIP control strategy that includes RACT requirements for existing 

stationary sources covered by Control Technology Guidelines (CTG) as applied in Ohio’s 

rural counties. 

Background: 

As required by Section 172 of the 1990 CAA Amendments, in the mid-1990’s 

Ohio promulgated rule requiring RACT for emissions of VOCs. There were 

no specific rules required by the CAA such as RACT for existing sources 

beyond statewide rules. 

Demonstration: 

Statewide RACT rules have been applied to all new sources locating in Ohio 

since that time. The Ohio rules are found in OAC Chapter 3745-21. 

 

Requirement 2 of 4:

Evidence that control measures required in past ozone SIP revisions have been fully 

implemented. 

Background: 

The U.S. EPA NOx SIP Call required 22 states to pass rules that would result 

in significant emission reductions from large EGUs, industrial boilers, and 

cement kilns in the eastern United States. Ohio passed this rule in 2001. 

Beginning in 2004, this rule will account for a reduction of approximately 31 

percent of all NOx emissions statewide compared to previous uncontrolled 

years. The other 21 states also have adopted these rules. 

Demonstration: 

U.S. EPA and Ohio EPA performed modeling that indicated this area would 

attain the eight-hour ozone standard with the implementation of the NOx SIP 

Call. Controls for EGUs formally commenced May 31, 2004. Emissions 

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 27 

covered by this program have been generally trending downward since 1998 

with larger reductions occurring in 2002 and 2003. Data taken from U.S. EPA 

Clean Air Markets Web site, quantifies the gradual NOx reductions that have 

occurred in Ohio as a result of Title IV of the 1990 CAA Amendments and the 

beginning of the NOx SIP Call Rule. Ohio developed the NOx Budget Trading 

Program rules in OAC Chapter 3745-14 in response to the SIP Call. OAC 

chapter 3745-14 regulated EGUs and certain non-EGUs under a cap and 

trade program based on an 85 percent reduction of NOx emissions from 

EGUs and a 60 percent reduction of NOx emissions from non-EGUs, 

compared to historical levels. This cap will stay in place through 2008, at 

which time the CAIR program will supersede it. 

U.S. EPA has recently published Phase II of the NOx SIP Call that 

establishes a budget for large (greater than 1 ton per day emissions) 

stationary internal combustion engines. Ohio EPA’s proposed rule OAC 

3745-14-12 addresses stationary internal combustion engines, all used in 

natural gas pipeline transmissions. An 82 percent NOx reduction from 1995 

levels is anticipated. Completion of the compliance plan is expected by May 

1, 2006 and the compliance demonstration will begin May 1, 2007. The 

2007 controlled NOx emissions will be 599 tons per day. 

Tier II Emission Standards for Vehicles and Gasoline Sulfur Standards 

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

emissions from cars and light trucks, including sport utility vehicles (SUVs). 

Under this proposal, automakers will be required to sell cleaner cars, and 

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

will apply nationwide. The federal rules will phase in between 2004 and 

2009. U.S. EPA has estimated that NOx emission reductions will be 

approximately 77 percent for passenger cars, 86 percent for smaller SUVs, 

light trucks, and minivans, and 65 to 95 percent reductions for larger SUVs, 

vans, and heavier trucks. 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. 

Heavy-Duty Diesel Engines 

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

program which includes low-sulfur diesel fuel standards, which will be phased 

in from 2004 through 2007. This rule applies to heavy-duty gasoline and 

diesel trucks and buses. This rule will result in a 40 percent reduction in NOx

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

inventory. 

Clean Air Non-road Diesel Rule 

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

applies to diesel engines used in industries such as construction, agriculture, 
 28 

and mining. It also contains a cleaner fuel standard similar to the highway 

diesel program. The new standards will cut emissions from non-road diesel 

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

in this rule, currently accounts for 47 percent of diesel particulate matter (PM) 

and 25 percent of NOx from mobile sources nationwide. Sulfur levels will be 

reduced in non-road diesel fuel by 99 percent from current levels, from 

approximately 3,000 ppm now to 15 ppm in 2009. New engine standards 

take effect, based on engine horsepower, starting in 2008. 

Together, these rules will substantially reduce local and regional sources of 

ozone precursors. 

Requirement 3 of 4:

Acceptable provisions to provide for new source review. 

Background: 

Ohio has a long standing and fully implemented New Source Review (NSR) 

program. This is addressed in OAC Chapter 3745-31. The chapter includes 

provisions for the Prevention of Significant Deterioration (PSD) permitting 

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

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

approval on January 22, 2003 (68FR 2909) by U.S. EPA as part of the SIP. 

Demonstration: 

Any facility that is not listed in the 2002 emission inventory, or for the closing 

of which credit was taken in demonstrating attainment, will not be allowed to 

construct, reopen, modify, or reconstruct without meeting all applicable 

permit rule requirement. The review process will be identical to that used for 

new sources. Once the area is redesignated, Ohio EPA will implement the 

NSR through the PSD program. 

Requirement 4 of 4:

Assure that existing controls will remain in effect after redesignation unless the state 

demonstrates through photochemical modeling that the standard can be maintained without 

one (1) or more controls. 

Demonstration: 

Ohio commits to maintaining the aforementioned control measures after 

redesignation. Ohio hereby commits that any changes to its rules or 

emission limits applicable to VOC and/or NOx sources, as required for 

maintenance of the ozone standard in Wheeling, WV-OH: Belmont County, 

will be submitted to U.S. EPA for approval as a SIP revision. 

Ohio, through Ohio EPA’s Legal section, has the legal authority and 

necessary resources to actively enforce any violations of its rules or permit 
 29 

provisions. After redesignation, it intends to continue enforcing all rules that 

relate to the emission of ozone precursors in Wheeling, WV-OH: Belmont 

County. 

LADCO Modeling Analysis for 8-Hour Ozone Standard Assessment 

LADCO performed modeling to evaluate the effect of the NOx SIP Call and 

Tier II / Low Sulfur rule for future year 2007 ozone in the Lake Michigan area. 

 This modeling was originally designed to assess the one-hour ozone 

standard. Further analysis was conducted and documented in the LADCO’s 

White Paper “8-Hour Ozone Assessment” dated May 2, 2001. Base year 

design values used were the average of the design values for the three (3) 

three-year periods (1994-1996, 1995-1997, and 1996-1998). Base year 

emissions were taken from 1996 and four (4) ozone episodes were 

evaluated: June 22-28, 1991; July 14-21, 1991; June 13-25, 1995; and July 

7-18, 1995. 

While modeling results were not calculated for the Wheeling, WV-OH: 

Belmont County area, the average decrease in ozone from the base case 

modeling run with modeling runs that applied emission controls required by 

the Clean Air Act, NOx SIP Call and Tier II /low-sulfur requirements was 15 

ppb (2009 Future design value of 73.3ppb*.) [* Midwest RPO Base K 2009 

Future Base case with on-the-books” including CAIR]. 

 LADCO Modeling for CAIR of 2004 

On March 10, 2004, U.S. EPA promulgated CAIR. NOx emissions will be cut 

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

million tons in 2018 in 28 eastern states and the District of Columbia. 

LADCO performed modeling to support the associated emission reductions 

for CAIR. This modeling was based on 2001 – 2002 design values for the 

Wheeling, WV-OH: Belmont County area. Results of the CAIR modeling 

show Wheeling, WV-OH: Belmont County will continue to attain the eighthour ozone NAAQS well into the future. 

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 30 

CHAPTER SIX 

CONTINGENCY MEASURES 

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

Requirement 1 of 4:

A commitment to submit a revised plan eight (8) years after redesignation. 

Demonstration: 

Ohio hereby commits to review its maintenance plan eight (8) years after 

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

Requirement 2 of 4:

A commitment to expeditiously enact and implement additional contingency control 

measures in response to exceeding specified predetermined levels (triggers) or in the event 

that future violations of the ambient standards occur. 

Demonstration: 

Ohio hereby commits to adopt and expeditiously implement necessary 

corrective actions in the following circumstances: 

 

Warning Level Response: 

A warning level response shall be prompted whenever an annual (1-year) 

fourth high monitored value of 88 ppb occurs in a single ozone season within 

the maintenance area. A warning level response will consist of a study to 

determine whether the ozone value indicates a trend toward higher ozone 

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 
 31 

necessary to reverse the trend taking into consideration ease and timing for 

implementation as well as economic and social considerations. 

Implementation of necessary controls in response to a warning level 

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

later than 12 months from the conclusion of the most recent ozone season 

(September 30). 

Should it be determined through the Warning Level study that action is 

necessary to reverse the noted trend, the procedures for control selection 

and implementation outlined under action level response shall be followed. 

 

 Action Level Response 

An action level response shall be prompted whenever a two (2) year average 

fourth high monitored value of 85 ppb occurs within the maintenance area. In 

the event that the action level is triggered and is not due to an exceptional 

event, malfunction, or noncompliance with a permit condition or rule 

requirement, Ohio EPA will determine additional control measures needed to 

assure future attainment of NAAQS for ozone. In this case, measures that 

can be implemented in a short time will be selected in order to be in place 

within eighteen (18) months from the close of the ozone season that 

prompted the action level. 

 Control Measure Selection and Implementation 

Adoption of any additional control measures is subject to the necessary 

administrative and legal process. This process will include publication of 

notices, an opportunity for public hearing, and other measures required by 

Ohio law for rulemaking by state environmental boards. 

If a new measure/control is already promulgated and scheduled to be 

implemented at the federal or state level, and that measure/control is 

determined to be sufficient to address the upward trend in air quality, 

additional local measures may be unnecessary. Furthermore, Ohio will 

submit to U.S. EPA an analysis to demonstrate the proposed measures are 

adequate to return the area to attainment. 

Requirement 3 of 4:

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

Demonstration: 

In the event that a violation of the ozone NAAQS is measured such that 

nonattainment is indicated at any ozone monitor in the Wheeling-Belmont 

nonattainment area operated in accordance with 40 CFR Parts 53 and 58, 

WVDEP and Ohio EPA will accordingly select and adopt one or more 

measures from the list provided below to assure continued attainment. The 

selection of measures will be based on cost-effectiveness, emission 
 32 

reduction potential, economic and social considerations or other factors that 

WVDEP and Ohio EPA deems appropriate. WVDEP in conjunction with Ohio 

EPA will solicit input from all interested and affected persons in the 

maintenance area prior to selecting appropriate contingency measures. 

Because it is not possible at this time to determine what control measure will 

be appropriate at an unspecified time in the future, the list of contingency 

measures outlined below is not comprehensive. 

1) Extend the applicability of 45 CFR 21 (VOC/RACT rule) to include 

 source categories previously excluded (e.g. waste water treatment 

 facilities). 

2) Revise new source permitting requirements requiring more stringent 

emissions control technology and/or emissions offsets. 

3) NOx RACT requirements if necessary. 

4) Regulations to establish plant-wide emission caps (potentially with 

 emissions trading provisions). 

5) Stage II Vapor Recovery regulations. 

6) Establish a Public Awareness/Ozone Action Days Program, a twopronged program focusing on increasing the public’s understanding of 

air quality issues in the region and increasing support for actions to 

improve the air quality, resulting in reduced emissions on days when 

the ozone levels are likely to be high. 

One or more of these regulatory revisions would be selected within three (3) months 

after verification of a monitored violation within forty-five (45) days of occurrence. 

For each regulatory revision selected, a draft rule will be developed by WVDEP and 

Ohio EPA within six (6) months of selection. The WVDEP and Ohio EPA will file the 

draft rule as an emergency rule and will become effective within forty-two (42) days 

after filing and fully implemented within six (6) months after adoption. Rule(s) will be 

filed as a legislative rule(s) for permanent authorization by the Legislature during the 

following legislative session. Therefore, less than eighteen (18) months should 

elapse from the time a violation occurs until an appropriate control measure is fully 

implemented. 

No contingency measure shall be implemented without providing the 

opportunity for full public participation during which the relative costs and 

benefits of individual measures, at the time they are under consideration, can 

be fully evaluated. 

Requirement 4 of 4:
 33 

A list of VOC and NOx sources potentially subject to future controls. 

Demonstration: 

The following is a list of VOC and NOx sources potentially subject to future 

controls. 

NOx RACT 

• EGUs 

• asphalt batching plants 

• industrial/commercial and institutional boilers 

• process heaters 

• internal combustion engines 

• combustion turbines 

• other sources greater than 100 tons per year 

VOC RACT 

• consumer products 

• architectural and industrial maintenance coatings 

• stage I gasoline dispensing facilities (including pressure valves) 

• automobile refinishing shops 

• cold cleaner degreasers 

• portable fuel containers 

• synthetic organic compound manufacturing 

• organic compound batch processes 

• wood manufacturing 

• industrial wastewater 

• aerospace industry 

• shipbuilding 

• bakeries 

• plastic parts coating 

• volatile organic liquid storage 

• industrial solvent cleaning 

• offset lithography 

• industrial surface coating 

• other sources greater than 50 tons per year 

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 34 

CHAPTER SEVEN 

PUBLIC PARTICIPATION

Ohio will publishpublished a notification for a public hearing and solicitation for public 

comment concerning the draft redesignation petition and maintenance plan in severala

widely distributed publicationspublication over 30 days prior to the public hearing. 

The public hearing to receive comments on the redesignation request will bewas held on 

July 27, 2006November 20, 2012, at the330 32nd Street, Bellaire, Ohio University Eastern 

Branch, Shannon Hall, Room 218, 45425 National Road, St. Clairsville, Ohio.. The public 

comment period will closeclosed on July 28, 2006. November 20, 2012. Appendix D will 

includeincludes a copy of the public notice, certifications of publication, and the transcript 

from the public hearing.
 35 

CHAPTER EIGHT 

CONCLUSIONS

The Wheeling, WV-OH: Belmont County basic nonattainment area has attained the 

NAAQS standard and complied with the applicable provisions of the 1990 CAA 

Amendments regarding redesignations of basic ozone nonattainment areas. 

Documentation to that effect is contained herein. Ohio EPA has prepared a state 

implementation and maintenance plan that meets the requirement of Section 110 (a)(1) of 

the 1990 CAA. 

Ohio has performed an analysis that shows the air quality improvements are due to 

permanent and enforceable measures. In addition, significant regional NOx reductions will 

ensure continued compliance (maintenance) with the standard and that all CAA 

requirements necessary for redesignation have been met. 

Based on this presentation, the Wheeling, WV-OH: Belmont County ozone basic 

nonattainment area meets the requirements for redesignation under the CAA and U.S. EPA 

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

significant regional NOx reductions will ensure continued compliance (maintenance) with 

the standards with an increasing margin of safety. 

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 36 

The State of Ohio hereby requests that the Wheeling, WV-OH: Belmont County ozone 

basic nonattainment area be redesignated to attainment simultaneously with U.S. EPA 

approval of the Ohio state implementation and maintenance plan provisions contained 

herein. 
 1 

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UNITES STATES ENVIRONMENTAL PROTECTION AGENCY

QUICKLOOK CRITERIA PARAMETERS

Report Request ID: 396663 Report Code: AMP450 Jan. 11, 2007

Selection Criteria Page 1

User ID: GYE

State County Site Parameter POC City AQCR UAR MSA CMSA

EPA

Region Method Duration Begin Date End Date

39

54

54

013

051

069

GEOGRAPHIC SELECTIONS

PROTOCOL SELECTIONS

Parameter

Classification Parameter Method Duration

CRITERIA 44201 W

SELECTED OPTIONS

MERGE PDF FILES

EVENTS PROCESSING

Option Type Option Value

YES

EXCLUDE REGIONALLY CONCURRED EVENTS

SORT ORDER

1

2

3

4

5

6

7

Order Column

PARAMETER_CODE

STATE_CODE

COUNTY_CODE

SITE_ID

POC

DATES

EDT_ID

GLOBAL DATES

2004

Start Date End Date

2006

Tribal
Jan. 11, 2007

Note: The * indicates that the mean does

not satisfy summary criteria.

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

AIR QUALITY SYSTEM

QUICK LOOK REPORT (AMP450)

Page 1 of 4

EXCEPTIONAL DATA TYPES

EDT DESCRIPTION

0

1

2

3

4

5

6

7

NO EVENTS

EVENTS EXCLUDED

EVENTS INCLUDED

EXCEPTIONAL EVENTS EXCLUDED

NATURAL EVENTS EXCLUDED

EVENTS WITH CONCURRENCE EXCLUDED

EXCEPTIONAL EVENTS WITH CONCURRENCE EXCLUDED

NATURAL EVENTS WITH CONCURRENCE EXCLUDED
Jan. 11, 2007

Note: The * indicates that the mean does

not satisfy summary criteria.

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

AIR QUALITY SYSTEM

QUICK LOOK REPORT (AMP450)

Page 2 of 4

Ozone (44201) West Virginia Parts per million (007)

SITE ID

P

O

C

REP

ORG CITY COUNTY ADDRESS YEAR METH

VALID

DAYS

MEAS

4TH

MAX

8-HR CERT EDT

54-069-0009

54-069-0010

54-069-0010

1

1

1

1151

1151

1151

Wheeling

Wheeling

Wheeling

Ohio

Ohio

Ohio

WHEELING EPA

(METHODIST

BLDG)

WARWOOD WATER

PLANT

WARWOOD WATER

PLANT

2004

2005

2006

112

112

112

.076

.097

.085

.072

.097

.083

Y

Y

0

0

0

8-HOUR 

NUM

DAYS

REQ

214

214

214

.067

.091

.079

.063

.089

.079

DAY

MAX>/=

0.085

0

6

1

213

214

180

%OBS

100

100

84

1ST

MAX

8-HR

2ND

MAX

8-HR

3RD

MAX

8-HR
Jan. 11, 2007

Note: The * indicates that the mean does

not satisfy summary criteria.

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

AIR QUALITY SYSTEM

QUICK LOOK REPORT (AMP450)

Page 3 of 4

44201 112 INSTRUMENTAL ULTRAVIOLET ABSORPTION

PARAMETER

METHOD

CODE COLLECTION METHOD ANALYSIS METHOD

METHODS USED IN THIS REPORT
Jan. 11, 2007

Note: The * indicates that the mean does

not satisfy summary criteria.

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

AIR QUALITY SYSTEM

QUICK LOOK REPORT (AMP450)

Page 4 of 4

REPORTING ORGANIZATIONS USED IN THIS REPORT

REPORTING

ORGANIZATION

CODE AGENCY DESCRIPTION

1151 West Virginia Northern Panhandle Regional Office
STREET ADDRESS: 

Lazarus Government Center 

122 S. Front Street 

Columbus, Ohio 43215 

CERTIFIED MAIL 

January 10, 2007 

State of Ohio Environmental Protection Agency 

TELE: (614) 644·3020 FAX: (614) 644·3184 

www.epa.state.oh.us 

Mr. Steve Rothblatt, Chief 

Air and Radiation Branch 

U.S.EPA, Region V 

77 West Jackson Boulevard 

Chicago, Illinois 60604 

RE: 2006 SLAMS Ozone Data Certification 

Dear Mr. Rothblatt: 

MAILING ADDRESS: 

P.O. Box 1049 

Columbus, OH 43216·1049 

Please find enclosed our SLAMS Reports (AMP-450 and AMP-240) for 

calendar year 2006 ozone data as required in 40 CFR, Part 58, 

Section 58.26. 

I certify that the data in the report are accurate to the best of 

our knowledge. There were no incidents of air pollution that 

reached or exceeded levels as specified by Section 51.151 which 

could cause significant harm to the he.alth of persons. 

Sincerely, 

Robert Hodanbosi 

Chief, Division of Air Pollution Control 

Enclosure 

@ Printed on Recycled Paper 

Bob Taft, Governor 

Bruce Johnson, Lieutenant Governor 

Joseph P. Koncelik, Director 

Ohio EPA is an Equal Opportunity Employer 
1

Ohio 

2002 Base Year SIP Inventory 

Ohio Environmental Protection Agency 

Lazarus Government Center 

122 South Front Street 

Columbus Ohio 43215 
2

Table of Contents 

Section Page 

 Introduction ................................................................................................ 3 

1.0 Point Sources ............................................................................................. 4 

 

2.0 Non Road Sources ..................................................................................... 8 

3.0 Area Sources ........................................................................................... 12 

4.0 MAR Sources ........................................................................................... 25 

5.0 On Road Sources ..................................................................................... 28 
3

2002 Base Year SIP Inventory for Ohio 

Introduction 

In April 2004, the United States Protection Agency (U.S. EPA) designated over 

400 counties nationwide as non-attainment for the new eight-hour ozone ambient 

air quality standard, including thirty three counties in Ohio. The 1990 Clean Air 

Act Amendments (CAAA) requires all states to revise and submit state 

implementation plans (SIPs) for areas which are classified as nonattainment of 

the National Ambient Air Quality Standards (NAAQS) for ozone. The following 

site provides a map of Ohio’s counties with either a Moderate or basic nonattainment designation: http://www.epa.state.oh.us/dapc/general/Ohio8-

Hour_Non-attainmentAreas0415204_1.pdf

As part of the designation of nonattainment areas for the eight-hour ozone 

standard, a new attainment demonstration SIP will be necessary. A key element 

in the overall SIP planning process is an updated emission inventory. This 

document presents the 2002 Base Year Ozone State Implementation Plan (SIP) 

Emissions Inventory for Ohio as required by the 1990 CAAA. It includes oxides 

of nitrogen (NOx) and volatile organic compounds (VOC) emissions for point, 

area, on-road mobile, non-road mobile and biogenic emissions for Ohio. 

This technical report documents the procedures and the methodologies that were 

used in the development of summer day volatile organic compound and nitrogen 

oxides emissions for all Ohio counties. This report describes the following: 

1. Identification of stationary and mobile sources included in the 

inventory; 

2. Sources of data, and data collection methods used in the 

development of the inventory; 

3. Methods and procedures used to estimate volatile organic and 

nitrogen oxides; and 

4. Assumptions considered in the development of emission 

inventories. 

The intent of this report is to describe how the inventory was prepared, and what 

information was considered in the inventory development. 

This document comprises of five sections; one section for each inventory 

category. The biogenic inventory is not being discussed in the document. Ohio 

EPA did not participate in the generation of the biogenic inventory. The Lake 

Michigan Air Directors Consortium (LADCO) utilized U.S. EPA’s Biogenic 

Emission Inventory System (BEIS) model in the Emission Modeling System 

(EMS) to generate summer weekday emissions for VOC and NOx. 
4

SECTION 1 

POINT SOURCES 

Emissions and source specific data for point sources are collected for the 2002 

base year SIP inventory by the Ohio Environmental Protection Agency (Ohio 

EPA.) The primary source of data for point sources is facility-reported STARShip 

files. STARShip is a software package developed by Ohio EPA, Division of Air 

Pollution Control (DAPC), to assist the regulated community in preparing and 

submitting a variety of electronic permit applications and reports to DAPC. 

These data are reported by the Title V facilities annually as part of the emissions 

fee/inventory process conducted by Ohio EPA and include emissions, process 

rates, operating schedules, emissions control data and other relevant 

information. The STARShip files are electronically transferred to DAPC and 

stored into the division’s Oracle database, STARS. The files are reviewed by the 

local air agencies and Ohio EPA district and central office staff. After review, the 

data are imported into Excel and linked with an Access® database to further 

process the information into the federally approved National Emission Inventory 

(NEI) database format in version 3.0. The files are quality assured again using 

U.S.EPA QA/QC software for format and content. The data are finally submitted 

to LADCO for emissions processing through the EMS. The State provided 

inventory for Electric Generating Units (EGU) is replaced with the federal EGU 

inventory. The EGU inventory is compiled by U.S. EPA’s Acid Rain Program. It 

is based on facility reported emissions as measured by continuous emissions 

monitors. In conclusion, the final point source inventory is a hybrid of the federal 

EGU inventory and the state provided non-EGU units. 

A major distinction typically made in emissions inventories is that between point 

and area sources. In this inventory, point sources are sources for which 

individual records are maintained for that source. Such records are maintained 

for all Ohio Title V facilities (753 facilities statewide). The area source inventory 

accounts for facilities from non-Title V facilities and calculates emissions 

information using surrogate emissions factors based on energy usage, 

population or other reliable data. A more detailed discussion of the area source 

inventory is provided in Section 3. The point source inventory described herein is 

considered to be the most current and accurate source of emissions data 

available for 2002. 

1.1 Point Source Process Emissions 

Ohio EPA defines point source process emissions as those which occur at an 

identifiable Title V stationary stack or vent. Point source emissions not emitted 

from discrete stacks or vents are termed fugitive emissions and are discussed in 

Section 1.2. 
5

1.1.1 Source Identification and Data Collection 

The sources to be included in the 2002 base year inventory are identified using 

the Title V STARS database. Facility production and emissions data are 

included in this database. This information is facility-reported actual 2002 

emissions. 

1.1.2 Non-reactive VOC Emission Adjustments 

Sources are required to identify emissions of photochemically non-reactive VOC. 

Based upon this information, those emissions have been specifically excluded 

from the 2002 base line inventory in accordance with U.S. EPA’s “Recommended 

Policy on the Control of Volatile Organic Compounds.” A complete list of the 

compounds that U.S. EPA has identified as being photochemically non-reactive, 

and therefore not included in the inventory, are listed below: 

• Methane 

• Ethane 

• Methylene chloride 

• Methyl chloroform 

• Trichlorofluoromethane (CFC-11) 

• Dichlorodifluoromethane (CFC-12) 

• Chlorodifluoromethane (CFC-22) 

• Trifluoromethane (HFC-23) 

• Chlorofluoromethance (HCFC-31) 

• Difluoromethane (HFC-32) 

• Decafluoropentane (HFC-43-10mee) 

• Ethylfluoride (HFC-161) 

• Trichlorotrifluoroethane (CFC-113) 

• Dichlorotetrafluoroethane (CFC-114) 

• Chloropentafluoroethane (CFC-115) 

• 2,2-Dichloro-1,1,1-trifluoroethane (HCFC-123) 

• 1,1,2-Trifluoroethane (HCFC-123a) 

• 2-Chloro-1,1,1,2-tetrafluoroethane (HCFC-124) 

• Pentafluoroethane (HFC-125) 

• 1,1,2,2,-Tetrafluoroethane (HFC-134) 

• 1,1,1,2-Tetrafluoroethane (HFC-134a) 

• 1,1-Dichloro-1-fluoroethane (HCFC-141b) 

• 1-Chloro-1,1,-difluoroethane (HCFC-142b) 

• 1,1,1-Trifluoroethane (HFC-143a) 

• Fluoroethane (HCFC-151a) 

• 1,1-Difluoroethane (HFC-152a) 

• Pentafluoropropane (HFC-225ca) 

• Pentafluoropropane (HFC-225cb) 

• Hexafluoropropane (HFC-236ea) 

• Hexafluoropropane (HFC-236fa) 

• Pentafluoropropane (HFC-245ca) 

• Pentafluoropropane (HFC-245ea) 

• Pentafluoropropane (HFC-245eb) 
6

• Pentafluoropropane (HFC-245fa) 

• Pentafluorobutane (HFC-365mfc) 

• Parachlorobenzotrifluoride (PCBTF) 

• Methoxybutane 

• Nonaflourobutane 

• Heptafluoropropane ((CF3)2CFCF2OCH3) 

• Heptafluoropropane ((CF3)CFCF2OC2H5) 

• Perchloroethylene 

• Cyclic, branched or linear completely methylated siloxanes 

• Methyl acetate 

• Volatile methyl siloxanes 

• Acetone 

1.1.3 Emissions Estimation Methodologies 

Since source reported actual annual emissions are used in the 2002 base year 

inventory, no estimation methods are necessary. The reports are provided to 

LADCO in National Emissions Inventory Input Format (NIF) 3.0 format. LADCO 

imported and processed the NIF files in EMS and applied temporal and spatial 

profiles to the annual emissions to calculate the July weekday emissions rates. 

The final point source inventory is split into two separate reports, the EGU which 

is the U.S. EPA inventory for electric generating units and the non-EGU which is 

the state inventory minus the EGU units. 

1.2 Point Source Fugitive Emissions 

Another type of emissions data which is required to be filed from point sources is 

fugitive emissions. Before 1990, fugitive emissions were categorized as area 

sources due to the lack of detailed information available for fugitive sources. 

However, since these emissions are now electronically reported in the state’s 

ORACLE database, STARS, these emissions can be classified as point sources. 

1.3 References 

Recommended Policy on the Control of Volatile Organic Compounds. U.S. 

Environmental Protection Agency, Research Triangle Park, NC, Revised January 

18, 1989. 

Procedures for the Preparation of Emission Inventories for Carbon Monoxide and 

Precursors of Ozone, Volume I: General Guidance for Stationary Sources. EPA450/4-91-016, Office of Air Quality Planning & Standards Research, Triangle 

Park, NC. May 1991. 

Compilation of Air Pollution Emission Factors, Fourth Edition and Supplements, 

AP-42. U.S. Environmental Protection Agency, Research Triangle Park, NC, 

September 1985. 
7

Guidance for the Preparation of Quality Assurance Plans for O3/CO SIP 

Emission Inventories. EPA-450/4-88-023, U.S. EPA Office of Air Quality Planning 

and Standards, Research Triangle Par, NC, December 1988. 

Documentation for the 2002 Electric Generating Unit National Emissions 

Inventory (NEI). Eastern research group, Inc., 1600 Perimeter Park Drive, 

Morrisville, NC 27560 and E.H. Pechan and Associates, Inc., 5528–B 

Hempstead Way 
8

SECTION 2 

NON-ROAD SOURCES 

The non-road inventory is generated regionally by running U.S. EPA’s National 

Mobile Inventory Model (NMIM) model. The Wisconsin Department of Natural 

Resources undertook the responsibility of customizing the NMIM input files and 

submit the output file in NIF format to LADCO and U.S. EPA. LADCO processed 

the NMIM files in their emissions model and generated summer emissions rates. 

Below are two e-mails from Grant Heatherington from the Wisconsin Department 

of Natural Resources that were distributed to the LADCO States. The first e-mail 

provides a summary of activities to revise the NMIM county profile files while the 

second e-mail provides an overall description of the modifications related to 

NMIM.

First e-mail from Grant Heaterington on NMIM Model and Input 

Descriptions 11/7/05 

2.1 Activity Data 

LADCO states: The activity data have been revised to include E. H. Pechan & 

Associates, Inc. (Pechan), an air quality consulting firm www.pechan.com, 

construction data. There are 130 source classification codes (SCC) impacted. 

The revised NMIM files are saved as five separate files: 1700002.act, 

1800002.act, 2600002.act, 3900002.act and 5500002.act even though each file 

is identical. These duplicates simplify the external file structures in NMIM. NonLADCO states: Minnesota provided revised activity data. The revised activity 

data are saved as 2700002.act. 

2.2 Allocation Data 

LADCO states: The allocation data have been revised to include Environ’s 

recreational marine data. The revised NMIM files are saved as 

17000wib_rev.alo, 17000wob_rev.alo, 18000wib_rev.alo, 18000wob_rev.alo, 

26000wib_rev.alo, 26000wob_rev.alo, 39000wib_rev.alo, 39000wob_rev.alo, 

55000wib_rev.alo and 55000wob_rev.alo. [“wib” stands for watercraft inboard 

and “wob” stands for watercraft outboard.] 

Non-LADCO states: Minnesota provided revised watercraft inboard, watercraft 

outboard and snowmobile allocation data. The revised NMIM files are saved as 

27000wib_rev.alo, 27000wob_rev.alo and 27000snm_rev.alo. [“snm” stands for 

snowmobile.] 

2.3 Emission Factor Data 

All states: The brake specific fuel consumption (BSFC) emission factor data have 

been revised to include Pechan’s data for diesel tampers/rammers 

(2270002006). The revised NMIM file is saved as revBSFC.EMF. 
9

2.4 Population Data 

LADCO states: The recreational marine and construction population data have 

been modified by Environ and Pechan respectively. The revised NMIM files are 

saved as 17000_rev.pop, 18000_rev.pop, 26000_rev.pop, 39000_rev.pop and 

55000_rev.pop files. 

2.5 Seasonality Data 

LADCO states: The recreational marine and agricultural seasonality data have 

been modified by Environ and Pechan respectively. The revised NMIM files are 

saved as 17000_rev.sea, 18000_rev.sea, 26000_rev.sea, 39000_rev.sea and 

55000_rev.sea. 

Non-LADCO states: For Iowa, Minnesota and Missouri, the agricultural 

seasonality data have been modified by Pechan. The revised NMIM files are 

saved as 19000_rev.sea, 27000_rev.sea and 29000_rev.sea. 

2.6 Growth Data

LADCO states: Pechan revised the growth file. The revised NMIM files are 

saved as five separate files: 17000_rev.grw, 18000_rev.grw, 26000_rev.grw, 

39000_rev.grw and 55000_rev.grw even though each file is identical. These 

duplicates are needed for the external file structures in NMIM. 

2.7 Fuel Data 

LADCO states: Pechan revised four tables (countyyear, countyyearmonth, 

datasource and gasoline) in the National County Database (NCD) used by NMIM 

to incorporate new fuel data. Additional revisions are incorporated into 2002 data 

for non-road Stage 2 controls. Depending on the year being modeled, different 

versions of the revised tables are used. Also, the countynrfile, countyyear and 

datasource tables are revised to reference the new activity, allocation, growth, 

population, and seasonality files described above. NCD tables with names 

ending in “def” are default versions of the table. See Table 2-1 for the 

appropriate versions of the tables for the selected years. 

Non-LADCO states: The countynrfile, countyyear and datasource tables are 

revised to reference the new activity, allocation and seasonality files described 

above. See Table 2-1 below for the appropriate versions of the tables for the 

selected years. 
10

Table 2-1 NMIM NCD Tables for Specific Years and States 

States Year 

2002 2007 – 2009, 2012 & 2018 

LADCO states countynrfile_rev_all, 

countyyear_rev_2002, 

countyyearmonth_rev_all, 

datasource_rev_all, 

gasoline_rev_all

countynrfile_rev_all, 

countyyear_rev_post_2002, 

countyyearmonth_rev_all, 

datasource_rev_all, 

gasoline_rev_all

MN countynrfile_rev_all, 

countyyear_rev_2002, 

countyyearmonth_def, 

datasource_rev_all, 

gasoline_def 

countynrfile_rev_all, 

countyyear_rev_post_2002, 

countyyearmonth_def, 

datasource_rev_all, 

gasoline_def 

IA and MO countynrfile_rev_all, 

countyyear_def, 

countyyearmonth_def, 

datasource_rev_all, 

gasoline_def 

countynrfile_rev_all, 

countyyear_def, 

countyyearmonth_def, 

datasource_rev_all, 

gasoline_def 

A more recent e-mail by Grant Heatherington on 5/26/2006, provides a synopsis 

of changes with no references to the file names 

Second e-mail mail from Grant Heatherington on NMIM Model and Input 

Descriptions 5/26/06 

The NMIM model developed by U.S. EPA, was used to estimate emissions for all 

other non-road mobile categories. NMIM consolidates non-road mobile 

emissions and on-road emissions modeling into a single modeling system. Only 

the non-road emissions modeling portion of NMIM was used in the development 

of this emission inventory. NMIM uses the U.S. EPA’s non-road model to 

calculate non-road mobile emissions. The basic non-road algorithm for 

calculating emissions uses base year equipment populations, average load 

factors, available engine powers, activity hours and emission factors. Before 

NMIM was run, modifications and additions were made to the NMIM input data 

and the non-road model. 

a. Revised activity data for construction equipment using updates 

provided by E.H. Pechan & Associates, Inc. Activity data describes 

typical usage for different types of non-road mobile equipment. 

b. Revised allocation data for recreational marine equipment using 

updates provided by ENVIRON International Corporation. 

Allocation data is used to spatially allocate emissions. 
11

c. Added emission factors for diesel tampers/rammers provided by 

E.H. Pechan & Associates, Inc. Diesel tampers/rammers are a 

type of construction equipment. 

d. Revised seasonality data for construction and recreational marine 

equipment using updates provided by E.H. Pechan & Associates, 

Inc. and ENVIRON International Corporation respectively. 

Seasonality data is used to temporally allocate emissions across 

the months of the year. 

e. Revised population data for construction and recreational marine 

equipment using updates provided by E.H. Pechan & Associates, 

Inc. and ENVIRON International Corporation respectively. 

f. Revised growth rates using updates provided by E.H. Pechan & 

Associates, Inc. If equipment populations aren’t provided for the 

modeled year (e.g. 2002), growth rates and scrappage rates are 

used to adjust the available equipment populations to the modeled 

year. 

g. Revised gasoline parameters using updates provided by the state 

and E.H. Pechan & Associates, Inc. Gasoline parameters include 

Reid vapor pressure (RVP), oxygenate content and sulfur content. 

h. Replaced the default version of the non-road model included with 

NMIM with an improved version that generates a more complete 

estimate of permeation emissions. The new version of the nonroad model was provided by Air Improvement Resources, Inc. 

Permeation emissions are due to the permeation of hydrocarbon 

molecules through plastic and rubber equipment components. 
12

SECTION 3 

AREA SOURCES 

Area sources are those sources which are typically small, individual and 

numerous, and have not been inventoried as specific point, mobile, or biogenic 

sources. For inventory purposes, these sources are grouped with other like 

sources into area source categories to allow emissions to be calculated 

collectively using one methodology. Area sources have been traditionally 

defined at the county level and therefore, most area source methods are 

designed to estimate area source emissions at the county level. 

Ohio EPA has either used published Emission Inventory Improvement Program 

(EIIP) methodologies or selected other methodologies which are shared by other 

states. The decision of which methodology to use was largely based on Ohio’s 

data availability. Data which was not available on a county-level is estimated by 

assigning a percentage of the state’s total activity to each county based on the 

state’s population or employment information. 

The area sources discussed in this document are those that emit NOX and/or 

VOC into Ohio’s atmosphere. Table 3-1 lists the categories included in the 2002 

area source inventory: 

Table 3-1 Categories included in the 2002 area source inventory 

VOC 

Emissions 

NOX & VOC 

Emissions 

NOX 

Emissions 

Agricultural Pesticides Residential Coal Combustion Human Cremation 

Architectural Surface Coatings Residential Distillate Oil Combustion 

Auto Body Refinishing Residential LPG Combustion 

Consumer & Commercial Solvents Residential Natural Gas Combustion 

Degreasing (Solvent Cleaning) Residential Wood Combustion 

Fuel Marketing Industrial Distillate Oil Combustion 

Graphic Arts Industrial Natural Gas Combustion 

Hospital Sterilizers Industrial Residual Oil Combustion 

Industrial Surface Coating Structure Fires 

Industrial Rubber & Plastics 

Landfills 

Portable Fuel Containers 

POTW 

Traffic Markings 
13

3.1 Agricultural Pesticides (SCC 246850000) 

 VOC 

Ohio farmers use mostly Atrizine and 2, 4-D chemicals in pesticide formulations 

for the three main crops: corn, soybean and wheat. According to Ohio’s 

Department of Agriculture, Ohio farmers use Atrizine pesticide with 42.6 percent 

active ingredient and 56.5 percent inert ingredient. The 2, 4-D pesticide contains 

46.8 percent active ingredient and 53.2 percent inert ingredient. While these 

percentages are not across the board, they represent the majority of what is 

being used. Ohio farmers use Atrizine and 2, 4-D in a liquid solution formulation 

type which is mixed with water when ready to use, and spray applied 90 percent 

of the time. 

The emission factor of 700 lb/ton for surface application for Atrizine and 2, 4-D is 

applied. To estimate the VOC emissions for all pesticides for each crop, an 

alternative method from the EIIP document is used because Ohio lacked the 

level of detail needed to calculate emissions for each pesticide formulation. 

E = VOC emissions 

A= Harvested acres 

R = Pounds of pesticide applied per year per harvested acre (see above). 

I = Pounds of active ingredient per pound of pesticide (assume a factor of one) 

ER = Evaporation rate (typically 0.9) (Wiens, 1977) 

3.2 Architectural Surface Coatings (SCC 2401001000) 

 VOC 

Architectural surface coatings is typically considered to be a non-industrial 

category which homeowners and painting contractors use for coating the interior 

and exterior of houses, buildings, and other surfaces. Two types of paint are 

used to categorize this area source: water-based and solvent-based paint. 

Solvent-based paint typically contains substantially higher volatile solvent 

contents than water-based paint. 

Table 3-2 lists the emission factors in calculating the VOC emissions which are 

acquired from the “Documentation for the 2002 Non-point Source NEI for Criteria 

Air Pollutants (CAPS) and Hazardous Air Pollutants (HAPS)”, January 2004, by 

Pechan1 and prepared for Emission Factor and Inventory Group (EFIG).

E(VOC) = A x R x I x ER x 2.45 
14

Table 3-2 VOC Emission Factors and Paint Usage Factors: 

Paint Type VOC Emission Factor

(lb/gal) 

Usage Factors 

(gal/person) 

Solvent-Based Paint 3.87 0.4158 

Water-Based Paint 0.74 2.0444 

The per capita usage factors are estimated by dividing the total volume of each 

type of coating shipped by the 2002 U.S. population2 288,368,698. 

3.3 Auto Body Refinishing (SCC 2401005000) 

 VOC 

The repairing of damaged vehicles to any coating applications which occur after 

those applied at the original manufacturers’ assembly plant are included in this 

category (only auto repair shops not coating of new cars). This area source 

includes paint and thinning solvents used as well as for surface preparation and 

clean-up. Since auto body repair shops may also be point sources, the area 

source emissions estimate will have to be adjusted by removing the total point 

source emissions. However, in Ohio, there are no point sources identified for 

this category so no such adjustment is made. 

The methodology is based on the per capita emissions factor because it is 

considered a more reliable factor that the employment factor. The VOC 

emissions factor (EF) of 1.3 lb/person is applied to each county’s population. 

This EF includes a thirty-three (33) percent promulgated rule reduction. 

3.4 Consumer & Commercial Solvents (SCC 2465000000) 

 VOC 

This area source includes a wide array of products including personal care 

products, household cleaning products and household pesticides. The majority 

of VOC emitted into the air from this category is a result of evaporation of the 

solvent contained in the product or from the propellant released during use. This 

category includes household use as well as businesses, institutions, and 

industrial manufacturing operations. 

Industrial solvent applications may also be point sources so adjustment must be 

made to the area source emissions by removing emissions due to point sources. 

However, in Ohio there are no point sources which contributed VOC emissions 

from this category. 

Ohio used the population2

 based methodology. A 7.3 lb/person EF is used to 

calculate VOC emissions. 
15

3.5 Solvent Cleaning (SCC 2415000000) 

 VOC 

This area source (also known as “degreasing”) includes two classifications: 

• Solvent Cleaning

– Cold Cleaning for Automobile Repair (2415360000) 

– Cold Cleaning for Manufacturing (2415345000) 

– Vapor/in-line Cleaning for Electronics & Electrical (2415230000) 

– Vapor/in-line Cleaning for Other (2415245000) 

• Solvent Cleanup 

– Wipe Cleaning of External Surfaces 

Ohio utilizes the methodology requiring employment3

 data. Each solvent-cleaning 

SCC identified above has an EF as indicated below in Table 3-4 which is used to 

calculate the VOC emissions by county. The resultant emissions are reduced by 

thirty (30) percent to account for the Maximum Achievable Control Technology 

(MACT) rules and are also reduced to account for point source emissions. 

Table 3-4 Solvent Cleaning SCC Emission Factors 

2415360000 270 lb/employee 

2415345000 24 lb/employee 

2415230000 29 lb/employee 

2415245000 9.8 lb/employee 

3.6 Fuel Marketing 

 VOC 

Truck Transit (SCC 2505030120) 

Gasoline tank trucks in transit are considered an evaporative loss of VOC 

emissions. This category consists of the VOC losses during the transit of 

gasoline in the trucks. The VOC calculation formula came from EIIP. Because 

gasoline may go through bulk gasoline plants before distribution to service 

stations, gasoline throughput figures are multiplied by 1.25 to estimate total 

gasoline transported. The total gasoline transported is multiplied with an EF of 

5.5 E-03 lb/1000 gallon transported for tank transit under loaded conditions and 

5.5 E-02 lb/1000 gallon transported for tank transit under unloaded conditions.
16

Filling Losses (SCC 2501060050) 

This category consists of the VOC loading losses from underground storage 

tanks during the transfer of fuel from the trucks. VOC calculations are based on 

ninety-five (95) percent submerged fill and five (5) percent splash for all counties. 

The VOC emissions calculation is also based on a ninety (90) percent rule 

effectiveness and a hundred (100) percent rule penetration. 

Standing Losses (SCC 2501060201) 

Breathing emissions losses from storage tanks occur during diurnal changes in 

barometric pressure, temperature and from gasoline evaporation. To calculate 

VOC emissions from the storage or breathing losses an EF of 1.000E+00 lb per 

1000 gallon gas throughput is used for all counties except of the 16 original nonattainment counties for ozone which employ a 1.000E-01 lb/1000 gallon of gas 

throughput. The value for the non-attainment counties was discussed with Bill 

Juris, Ohio EPA-DAPC and familiar with Ohio’s gasoline dispensing facilities 

(GDF) VOC regulations and practices.

Gasoline Distribution Stage 2 (SCC 2501060100 & 250106103) 

Vehicles refueling at service stations are the source of VOC emissions as vapors 

are displaced from automobile tanks during filling (2501060100) and from 

spillage (2501060103) of gasoline. The quantity of displaced vapors is based on 

gasoline throughput and is affected by gasoline temperature, gasoline volatility 

and, most importantly, by the presence of vapor recovery equipment. Stage II 

vapor recovery equipment is required at all service stations in the 16 original nonattainment counties for ozone that market in excess of 10,000 gallons per month. 

The VOC emissions factor for filling operations is 1.0E+01 lbs/1000 gallons. For 

the 16 counties that are subject to controls, a control efficiency of ninety-five (95) 

percent with ninety (90) percent rule effectiveness and a ninety (90) percent rule 

penetration is used in the calculation of emissions. The VOC emissions factor 

for spillage is 0.7 lbs/1000 gallons of gasoline for the 72 unregulated counties 

and 0.4 lbs/1000 gallons of gasoline for the controlled counties. 

Since the actual gallons of gasoline sold in each county could not be obtained, 

the methodology uses the vehicle miles traveled (VMT) data and the State’s 

consumption of gasoline to apportion the gasoline consumption within a county. 

3.7 Graphic Arts (SCC 2425000000) 

 VOC 

This area source includes printing of newspaper, books, magazines, fabrics and 

other materials. VOC emissions from this category are calculated using Ohio’s 

population5

 rather and the per capita emissions factor for VOC of 1.3 lb/year. 
17

3.8 Hospital Sterilizers (SCC 2850000010) 

 VOC 

Small amounts of ethylene oxide (EO) are used in sterilization of hospital surgical 

equipment and plastic devices that cannot be sterilized by steam. EO is used as 

a sterilizer because of its potency and effectiveness in destroying pathogens 

without damaging the integrity of the device. The methodology used to calculate 

EO emissions in Ohio called for the number of beds in each hospital size to use 

the appropriate EF. Based on national sales of EO in 2002, Ohio’s EO 

emissions are calculated to be 7.3 tons (based on Ohio’s share of hospital beds 

of 3.5 percent). 

3.9 Industrial Rubber/Plastics (SCC 2430000000) 

 VOC 

This category is calculated using employment3

 data for each county for the 

following North American Industry Classification System (NAICS): 

31332 32613 32614 32615 32616 32621 

32622 316211 325991 326113 326121 326122 

326191 326199 326291 326299 335121 339991 

A VOC EF of 203 lbs/employee is recommended to estimate the area source 

VOC estimate. Even after subtracting the point source VOC contribution (1116 

annual tons of VOC), this category would have been the highest category of 

emissions. After raising this issue with other states in the LADCO region, it is 

decided that the emissions factor has a high degree of uncertainty and it will 

significantly skew the overall VOC estimate from the area source categories. This 

category is left out from the emissions table but it is kept here for documentation. 

3.9 Industrial Surface Coating 

 VOC 

This area source contains several categories as listed below in Table 3-5. The 

appropriate NAICS codes are used for each category, shown in Table 3-6, to 

obtain employment data3

 from Bureau of Labor Statistics for each county. Net 

VOC emissions are calculated by subtracting the portion of VOC contributed from 

point sources. 
18

Table 3-5 Categories included in Area Sources 

 CATEGORY SCC NAICS VOC EF 

Factory Finished Wood 2401015000 321 131 

Lb/employee/year 

Furniture and Fixtures 2401020000 337 944 

Lb/employee/year 

Metal Containers 2401040000 332431 6029 

Lb/employee/year 

Sheet, Strip and Coil 2401045000 332812 2877 

Lb/employee/year 

Machinery & Equipment 2401055000 333 77 Lb/employee/year

Large Appliances 2401060000 3352 463 

Lb/employee/year 

Electrical Insulation 2401065000 334 290 

Lb/employee/year 

Automobiles (new) 2401070000 3361 794 

Lb/employee/year 

Other Transportation 

Equipment 2401075000 336 35 Lb/employee/year

Marine Coatings 2401080000 3366 308 

Lb/employee/year 

Other Product Coatings 2401090000 339 0.6 Lb/person/year 

High Performance 

Coatings 2401100000 811 0.8 Lb/person/year 

Other Special Purpose 2401200000 NOT DONE 0.8 Lb/person/year

Table 3-6 NAICS Codes Used for Area Sources 

Automobile Repair 488490, 441110, 441120, 4471, 441222, 441210, 

81111 

Manufacturing 337, 331, 332, 333, 335, 336, 334, 339 

Electronics and Electrical 335 

Other 337, 337, 331, 332, 333, 335, 336, 334, 339, 

488490, 441110, 441120, 4471, 441222, 441210, 

8111 

3.10 Municipal Solid Waste (SCC 2620030000) 

 VOC 

The methodology for methane gas emissions from landfills requires the tonnage 

deposited in the landfills for the last 25 years. However, Ohio EPA’s Division of 

Solid and Infectious Waste’s input data only spanned 20 years. Therefore, any 

landfill which did not record or report its waste intake for that period was not 

included in the database. Landfills with controls are identified as having flares. 

The preferred method is used which is based on landfill capacity and tonnage 

input of waste and the number of years the landfill operated and the number of 
19

years it has been closed. A seventy five (75) percent collection efficiency and a 

ninety-five (95) percent control efficiency are used per AP-42 Compilation of Air 

Pollutant Emission Factors. 

The toxic pollutants are calculated using the methane production rate and the 

EIIP calculation formula that involves the compound molecular weight and the 

co-disposal factor. The VOC emissions are equal to the emissions from all toxics 

minus methylene chloride, mercury, and perchloroethylene (PERC.) 

3.11 Portable Fuel Containers 

 VOC 

 RESIDENTIAL 2501011010 / COMMERCIAL 2501012010 

This area source’s VOC is the sum of emissions obtained from both commercial 

and residential containers. The residential and commercial container total 

emissions for the year are based on 250 days per year and include losses from 

refueling vapor displacement, permeation, diurnal, equipment refueling spillage, 

and transport-spillage. Emissions estimates are based on population2

 and 

consistent with California’s approach. Although the California methodology 

generates rather high emissions estimates, it is the only available estimate at the 

time of generating the 2002 inventory. 

3.12 POTW (SCC 2630020000) 

 VOC 

Ohio EPA’s Division of Surface Water does not review minor flows because they 

are not mandated by U.S. EPA. Therefore, Ohio’s wastewater flow data only 

represents eighty (80) percent of the total flow for this area source category. A 

twenty (20) percent increased flow is added to compensate for Publicly Owned 

Treatment Works (POTW) facilities which are not part of Ohio’s database. The 

VOC emissions factor is based on the Pennsylvania (PA) factor of the 1996 

Protocol. 

The 1996 EIIP methodology only offered EF for HAPs. Ohio’s VOC emissions 

for this category are calculated based on an EF obtained from the PA 1996 

Protocol which was the factor being used at the time of this inventory. 

3.13 Traffic Markings (SCC 2401008000)

 VOC

The number of lane miles per county is obtained from Ohio’s Department of 

transportation. The national gallon of traffic markings are apportioned to the 

state using the ratio of state dollar disbursements in relation to the national 

disbursement. The county level apportionment of paint2 is made using the 

number of lane miles. The VOC factor (3.36 lb/gal) is calculated based on Ohio's 

assumption of ninety (90) percent water based and ten (10) percent oil based 

paint. 
20

3.14 Human Cremation (SCC 2810060100) 

 NOX

Not all Ohio counties possess a crematory so only those counties with 

crematories are used to calculate the number of cremations. These numbers are 

adjusted to account for the cremation of bodies which are brought in from out of 

county since the calculations are based on number of deaths per county2. Ohio 

has an eighteen (18) percent cremation rate. Particular matter (PM) emissions 

are calculated for this category but the methodology did not call for the 

calculation of NOX emissions so they are not calculated. Furthermore, since 

current NOX EF in Ohio’s crematory permits vary significantly, the EIS program 

will develop a less variable one for future use in inventory NOX calculations. 

3.15 Industrial Fuel Combustion 

 VOC & NOX

Industrial Distillate Oil Combustion (SCC 2102004000) 

Ohio’s fuel consumption is apportioned per county based on the county’s 

population5

. The area source VOC and NOX emissions are calculated and 

adjusted to subtract the emissions due to point sources. A heating value of 140 

mmbtu/1000 gallon is used and 4,795,000 barrels are consumed in 2002. 

[MMBTU stand for Million British Thermal Units]. 

Industrial Residual Oil Combustion (SCC 2102005000) 

Ohio’s fuel consumption is apportioned per county based on the county’s 

population5. The area source VOC and NOX emissions are calculated and 

adjusted to subtract the emissions due to point sources. There are 1,806,000 

barrels consumed and a heating value of 140 mmbtu/1000 gallon is used. 

Industrial Natural Gas Combustion (SCC 2102006000) 

Ohio’s fuel consumption is apportioned per county based on the county’s 

population5

. The area source VOC and NOX emissions are calculated and 

adjusted to subtract the emissions due to point sources. 

3.16 Residential Fuel Combustion 

 VOC & NOX

Residential Coal Combustion (SCC 2104001000) 

Ohio’s household consumption of coal is apportioned per county based on 

county population5

. NOX and VOC emissions are calculated using EF of 9.1 and 

10 lb/ton of coal respectively. 

Residential Distillate Oil Combustion (SCC 2104004000) 

Ohio’s household consumption of distillate oil is apportioned per county based on 

county population5. NOX and VOC emissions are calculated using EF of 18 and 
21

0.71 lb/1000 gallons distillate fuel respectively. A heating value of 140 

mmbtu/1000 gallon is used. 

Residential Liquid Petroleum Gas Combustion (LPG) 

(SCC 2104007000) 

Ohio’s household consumption of LPG is apportioned per county based on 

county population5

. NOX and VOC emissions are calculated using EF of 13 and 

0.49 lb/1000 gallons LPG respectively. There are 11,432 barrels estimated to be 

used in 2002. 

Residential Natural Gas Combustion (SCC 2104006010) 

Ohio’s household consumption of LPG is apportioned per county based on 

county population5. NOX and VOC emissions are calculated using EF of 94 and 

5.5 lb/MMSCF respectively. [MMSCF stands for Million Standard Cubic Feet]. 

Residential Wood Combustion 

VOC and NOX emissions from this area source are estimated for seven types of 

equipment that may be used for residential heating involving wood. They are 

listed below with the appropriate SCC: 

Fireplaces without inserts 2104008001 

Fireplaces with inserts catalytic (non-U.S. EPA cert) 2104008002 

Fireplaces with inserts non -catalytic 2104008003 

Fireplaces with inserts catalytic (U.S. EPA cert) 2104008004 

Wood stoves – Conventional 2104008010 

Woodstoves – Catalytic 2104008030 

Wood stoves – Non catalytic 2104008050 

The number of Ohio homes with fireplaces are adjusted for those that burn wood. 

The following assumptions are applied to those adjusted homes: 

92 percent of wood combusted in non-certified units 

5.7 percent of wood combusted in non-catalytic units 

2.3 percent of wood combusted in catalytic units 

A state consumption value is applied which is apportioned to each county based 

on a county’s population. Table 3-7 shows the EF used for each of the seven 

types of wood burners which make-up this category: 
22

Table 3-7 Emission Factors Used for Wood Burners included in Area 

 Sources 

SCC 2104008002 2104008003 2104008004 

SCC 2104008010 2104008050 2104008030 

SCC 2104008001 

RAPIDS Code Non-Certified Non-Catalytic Catalytic Units 

VOC 53 12 15 Lb/ton 

NOX 2.80E+00 2.80E+00 2.00E+00 Lb/ton 

3.17 Structure Fires (SCC 2810030000) 

 VOC & NOX

This area source is considered a combustion source for VOC and NOX emissions 

which is calculated using EF of 11 and 1.4 lb/ton burned respectively. The 

residential and commercial structures fires for each county are tabulated and a 

fuel loading per fire EF of 1.15 ton/fire is applied. 

3.18 Miscellaneous Categories 

Although the area sources described above are the categories which contribute 

VOC & NOX emissions into Ohio’s ambient air, other area sources are calculated 

as well. These additional sources are listed below and contribute the associated 

pollutants into Ohio’s air. 

Dry Cleaning Perchloroethylene 

Lamp breakage Mercury 

The following area sources are attempted to be calculated but due to insufficient 

Ohio data available or unreliable emissions factors, they remain incomplete. 

Asphalt Paving VOC 

Forest Fires VOC & NOX

Gas & Oil Production VOC 

Open Burn VOC 

3.19 References 

1. Documentation For the 2002 Non-Point Source National Emission Inventory 

For CAPS and HAPS. U.S. Environmental Protection Agency. Emissions 

Factor and Inventory Group. E.H Pechan and Associates, Inc. January 2004. 

2. United States Census Bureau. Population Division. 

http://eire.census.gov/popest/data/counties/tables/CO-EST2002/COEST2002-01-39.php 

 (Accessed 2003) 
23

3. United States Census Bureau. County Business Patterns. 

http://censtats.census.gov/cbpnaic/cbpnaic.shtml

 (Accessed 2003) 

Pesticides - Agricultural and Non-Agricultural. U. S. Environmental Protection 

Agency. Emissions Inventory Improvement Program. Eastern Research Group, 

Volume III. Chapter 9, June 2001. 

Agricultural Chemical Use. U. S. Department of Agriculture. National 

Agricultural Statistics Service. 

http://usda.mannlib.cornell.edu/reports/nassr/other/pcu-bb/agcs0503.txt 

(Accessed 2003) 

Telephone conversation with Diane Roll. Ohio Department of Agriculture, 

Columbus, Ohio. Percentage of active ingredients and method of application. 

Daily Vehicle Miles Traveled Reports. Ohio Department of Transportation, Office 

of Technical Services. http://dot.state.oh.us/techservsite/availpro/Road_ 

Infor/KDVMT/kDVMT.htm (Accessed 2003) 

Motor Vehicle Fuel Tax. Ohio Department of Taxation. www.state.oh.us/tax

(Accessed 2003) 

Advancing Health in America Guide. Health Forum. American Hospital 

Association. 2001-2002 

Documentation for the Draft 1999 National Emissions Inventory (Version 3.0) For 

Criteria Air Pollutants and Ammonia. Area Sources. E. H. Pechan & Associates, 

Inc. March 3, 2003 

Compilation of Air Pollutant Emission Factors, Fourth Edition and Supplements, 

AP- 42, U.S. Environmental Protection Agency, Research Triangle Park, NC, 

September 1985 landfill.

Landfills. U. S. Environmental Protection Agency. Emissions Inventory 

Improvement Program. Eastern Research Group Volume III: Chapter 15. 

January 2001. 

Ohio EPA, Division of Solid & Infectious Waste. Columbus, Ohio. 

California’s Portable Gasoline Container Emissions Inventory. Air Resources 

Board Mobile Source Control Division. California Air Resource Board Inventory 

method (September 23, 1999). http://www.arb.ca.gov/homepage.htm. (Accessed 

2003). 
24

Spreadsheet formulation provided by “Buzz” David Asselmeier, Air Quality 

Planning Section, Inventory Group, Springfield, Illinois. 

Ohio EPA Division of Surface Water. Columbus, Ohio. 

Paint and Allied Products: 2002. U.S. Census Bureau. U.S. Department of 

Commerce. Economics and Statistics Administration. 

http://www.census.gov/industry/1/ma325f02.pdf 

(Accessed 2003) 

Highway Statistics 2002. Federal Highway Administration. U. S. Department of 

Transportation. http://www.fhwa.dot.gov/policy/ohim/hs02/sf2.htm 

(Accessed 2003) 

Ohio Department of Transportation. Columbus, Ohio. 

Cremation Association of North America. 

http://www.cremationassociation.org/docs/Web01Prelim.pdf (Accessed 2003) 

State of California Air Resources Board Test Report 

http://www.arb.ca.gov/homepage.htm (Accessed 2003) 

Industrial Sector Energy Price and Expenditure Estimates, 1970-2001, Ohio. 

Energy Information Administration. U. S. Department of Energy. 

http://www.eia.doe.gov/emeu/states/sep_prices/ind/pr_ind_oh.html

http://www.eia.doe.gov/emeu/aer/pdf/pages/sec1_27.pdf (Accessed 2003) 

Ohio Department of Commerce. State Fire Marshal Division. Columbus, Ohio. 

http://www.com.state.oh.us/odoc/sfm/firecont.htm (Accessed 2003) 
25

SECTION 4 

MARINE, AIRCRAFT and RAIL (MAR) SOURCES 

MAR sources are those non-road sources which are significant enough in terms 

of emissions to be considered separately from the rest of the non-road sources. 

The MAR inventory consists of commercial marines, aircraft and locomotive 

sources. The marine and locomotive inventory is generated by Environ1

 under 

contract with LADCO and the aircraft inventory is generated by U.S. EPA. 

4.1 Marine Vessel Sources 

Commercial marines consist of several different categories of vessel types and 

for each category there are unique activity data sources, engine types and 

emissions rates. A summary of commercial marine activity categories and data 

sources is shown at Table 4-1. 

Table 4-1 Summary of Commercial Marine Activity Categories and Data 

 Sources 

Commercial 

Marine Activity 

Spatial Range Activity Estimation Data Source 

Large Deep Draft Near Port Ports and Army Corps of Engineers 

Large Deep Draft Mid Lake Army Corps of Engineers 

Barge Traffic Inland Rivers Tennessee Valley Authority Fuel 

Consumption Estimation 

Barge Traffic Lake Traffic Army Corps of Engineers Freight 

Carried 

Tug Near Port Coast Guard Vessel List and 

Selected Surveys 

Ferries Regular Route Coast Guard Vessel List and 

Selected Surveys 

Excursion Near Home Port Coast Guard Vessel list 

Dredging Area by Contract Army Corps of Engineers Contracts 

Commercial Fishing Dock State Registration 

Military Near shore and 

Mid-Lake 

Coast Guard Fuel Purchases 

The procedure that is followed in estimating emissions for each commercial 

marine category or boat type is documented by Environ1

. The summary of 

commercial marine emissions estimate for Ohio is 248 tons of VOC and 10,307 

tons of NOX. This is significantly lower than what is estimated by NEI for 1999 

which was 1376 tons of VOC and 44,020 tons of NOX. 
26

4.2 Locomotive Sources 

Locomotives are usually the most important source of NOX from non-road 

engines. This category is especially important for Ohio because the State is an 

important rail center. Rail activity is typically broken into five subcategories. 

These subcategories are listed in Table 4.2. 

Table 4.2 Rail Categories 

SCC Description Comment 

2285002006 Class I operations Norfolk Southern (NS), CSX 

2285002007 Class II/III operations Regional and local railroads 

2285002008 Passenger Trains AMTRAK 

2285002009 Commuter Lines METRA 

2285002010 Yard Operations Class I yard rail and small 

switching railroads 

Because the Class I railroads are expected to be the most significant rail 

operations in most areas, every Class I railroad is asked for information about its 

rail operation. Norfolk Southern (NS) and CSX provided estimates for their fuel 

consumption by rail line for line-haul estimates but are unable to detail their 

switching rail activity. They provided activity by county in terms of ton-mile of 

freight movement and estimated fuel consumption using typical system-wide fuel 

consumption per ton-mile. The Class II rail estimate which is of lesser 

importance than the Class I rail is based on national consumption and an 

employee emissions factor of 10,000 gallons per employee. The passenger rail 

estimate is based on information provided by AMTRAK on the weekly schedule 

of trains and emissions are based on 2.35 gallons per train-mile fuel 

consumption. Emissions factors and detailed calculation procedures are 

documented on the Environ1 study and it is referenced at the end of this section. 

4.3 Aircraft Vessel Sources 

U.S. EPA contracted with ERG Consulting Firm http://www.erg.com/ to generate 

this inventory. The estimate is based on information collected by the Federal 

Aviation Administration (FAA) on published (landing and take-off) LTO cycle by 

engine type for each airline and major airport in the state. The LTO is multiplied 

by emissions factors developed by the International Civil Aviation Organization 

(ICAO). Finally, the LTO data are combined and entered into the FAA Emissions 

and Dispersion Modeling System (EDMS), which is designed to calculate aircraftspecific emissions. 

For all of the above three categories, LADCO processed the data in EMS 2003 to 

calculate summer day emissions for VOC and NOX. The tables are provided as 

an attachment. 
27

4.4 References 

LADCO Non-road Emissions Inventory Project for Locomotive, Commercial 

Marine and Recreational Marine Emission Sources, prepared by Christian E. 

Lindhjem, ENVIRON International Corporation, September 8. 2004. 
28

SECTION 5 

ON-ROAD SOURCES 

A mobile source of air pollution is a self-propelled or portable emitter of air 

pollutants, and mobile source emissions are those generated by the engines or 

motors that power such sources. Most mobile sources, except jet or turboprop 

aircraft, are powered by internal combustion (IC) piston engines, and nearly all 

use liquid fuels. 

Gaseous fuels, such as compressed natural gas (CNG) or liquefied petroleum 

gas (LPG), had only a very small fraction of the motor fuel market in Ohio in 

2002. Solid fuels have not been used by mobile sources in significant amounts 

since railroads retired their coal-powered steam locomotives in the 1950s. 

5.1 Categories of Mobile Sources 

For inventory and planning purposes, mobile sources are divided into two major 

categories. 

1. On-highway mobile sources, i.e., motor vehicles such as cars, vans, 

trucks, buses and motorcycles used for transportation of goods and 

passengers on roads and streets. 

2. Off-highway (usually referred to as non-road) mobile sources including: 

• Modes of powered transportation that do not use roads, such as 

aircraft, trains, ships and boats, and motor vehicles used off-road. 

• Self-propelled or portable motorized machines or equipment not used 

for transportation, ranging from construction equipment and farm 

tractors to lawnmowers and hand-held power weed choppers. 

Mobile Sources: All on-highway mobile sources are self-propelled. 

Non-road Mobile Sources: Some non-road mobile sources (e.g., farm tractors), 

are self-propelled, but many non-road sources are not. A gasoline-powered 

chain saw is a familiar example of a non-self-propelled non-road mobile source. 

Stationary Sources: Not all movable or portable emission sources are mobile 

sources, however. A small truck-portable cement or hot-mix asphalt plant, for 

example, may be set up near a construction or road-building site. Such plants 

are classified as stationary sources, not mobile sources for two reasons: (1) they 

may operate for weeks or months at a single location, and (2) the trucks that 

move the plants do not supply power for them. 
29

NOTE: Not all IC or turbine engines are mobile sources. Fixed IC engines, such 

as those that power pipeline compressors or standby generators in electricity 

plants and elsewhere, are also classified as stationary sources. 

5.1.1 Categories and Components of Mobile Source Emissions 

There are three categories of mobile source emissions: 

• Exhaust or tailpipe emissions, which result from the combustion of fuel in 

the source’s engine 

• Evaporative emissions, which result from evaporation of fuel from the 

engine or it’s fuel system 

• Refueling emissions 

Exhaust Emissions: Are the result of fuel combustion and occur only when the 

engine is running. 

Evaporative emissions: Are VOC based only and are continuously emitted 

from an engine’s fuel system, whether the engine is running or not. Gasoline is a 

very volatile fuel, so total VOC emissions from gasoline powered vehicles have a 

large evaporative component. Diesel and jet fuels are of very low volatility, so 

evaporative emissions from diesel and turbine engines are a much smaller part 

of their total VOC emissions. Evaporative emissions for CNG or LPG powered 

vehicles are negligible because their fuel tanks and systems are of necessity, 

sealed. 

Evaporative and exhaust VOC emissions can be calculated separately for most 

mobile source categories, but in this inventory these two components are 

combined into total VOC. Evaporative emissions do not include VOC emissions 

that occur during refueling. 

Refueling Emissions: Are the third category of mobile source emissions. 

Refueling emissions are entirely VOC. Although they result from the evaporation 

of fuel, they are distinct from, and not directly related to, evaporative emissions 

as defined above. 

Refueling emissions have two subcomponents: 

• Displacement emissions. These occur when new fuel is transferred into a 

partly filled tank--be it a service station storage tank, a portable fuel 

container (gas can), or a vehicle or engine’s fuel tank; displacing the air in 

the tank and forcing that vapor-rich air out the inlet pipe or other vent. 

There are two stages of displacement emissions: 
30

o “Stage I” emissions occur when the underground storage tanks at a 

service station are being refilled; 

o “Stage II” emissions occur when a motor vehicle (or gas can) is 

being refueled. 

NOTE: These emissions are covered in, “Area Sources,” section 3.6. 

• Spill emissions. These occur when drops of fuel drip or splash on the 

ground during or after refueling and evaporate away. 

5.2 Ohio On-Highway Mobile Source Inventory 

The inventory of on-highway mobile source emissions was developed in 

conjunction with the Ohio Department of Transportation (Ohio DOT), LADCO, 

U.S. EPA, and the Ohio EPA. Estimates of the amounts of NOx and VOC are 

reported by county in tons per day. Emissions are reported for a typical ozone 

season weekday in the summer of 2002. 

5.2.1 Emission Inventories Developed with MOBILE6.2 Model 

MOBILE6.2 Overview: 

MOBILE6.2 is a computer program that estimates hydrocarbon (HC), carbon 

monoxide (CO), NOx, exhaust particulate matter (which consists of several 

components), tire wear particulate matter, brake wear particulate matter, sulfur 

dioxide (SO2), ammonia (NH3), six hazardous air pollutant (HAP), and carbon 

dioxide (CO2) emission factors for gasoline-fueled and diesel highway motor 

vehicles, and for certain specialized vehicles such as natural-gas-fueled or 

electric vehicles that may replace them. The program uses the calculation 

procedures presented in technical reports posted on U.S. EPA's MOBILE6.2 

Web page http://www.epa.gov/otaq/models.htm. 

MOBILE6.2 emission factor estimates depend on various conditions, such as 

ambient temperatures, travel speeds, operating modes, fuel volatility, and 

mileage accrual rates. Many of the variables affecting vehicle emissions can be 

specified by the user. MOBILE6.2 will estimate emission factors for any calendar 

year between 1952 and 2050, inclusive. Vehicles from the 25 most recent model 

years are considered to be in operation in each calendar year. 

5.2.2 MOBILE6 Defaults: 

MOBILE6.2 includes default values for a wide range of conditions that affect 

emissions. These defaults are designed to represent “national average” input 

data values. Users who desire a more precise estimate of local emissions can 

substitute information that more specifically reflects local conditions. Use of local 
31

input data will be particularly common when the local emission inventory is to be 

constructed from separate estimates of roadways, geographic areas, or times of 

day, in which fleet or traffic conditions vary considerably. 

A list of MOBILE6.2 input parameters is provided below. Most of these inputs are 

optional because the model will supply default values unless alternate data are 

provided. 

5.2.3 MOBILE6 Input Parameters 

• Calendar year

• Month (January, July) 

• Hourly Temperature 

• Altitude (high, low) 

• Weekend/weekday 

• Fuel characteristics (Reid vapor pressure, sulfur content, 

 oxygenate content, etc.) 

• Humidity and solar load 

• Registration (age) distribution by vehicle class 

• Annual mileage accumulation by vehicle class 

• Diesel sales fractions by vehicle class and model year 

• Average speed distribution by hour and roadway 

• Distribution of vehicle miles traveled by roadway type 

• Engine starts per day by vehicle class and distribution by hour 

• Engine start soak time distribution by hour 

• Trip end distribution by hour 

• Average trip length distribution 

• Hot soak duration 

• Distribution of vehicle miles traveled by vehicle class 

• Full, partial, and multiple diurnal distribution by hour 

• Inspection and maintenance (I/M) program description 

• Anti-tampering inspection program description 

• Stage II refueling emissions inspection program description 

• Natural gas vehicle fractions 

• HC species output 

• Particle size cutoff 

• Emission factors for PM and HAPs 

• Output format specifications and selections

5.2.4 MOBILE6 References 

The following publications provide much of the guidance for the preparation of 

the on-highway inventory. 
32

EPA-450/4-81-026d (Revised), now EPA/450-R-92-009, Procedures for 

Emission Inventory Preparation, Volume IV: Mobile Sources, December 

1992. Hereafter “Procedures Vol. IV”. The 1992 version is still the definitive 

document on inventories. If a previous edition is referred to, the fact will be 

noted as, for example, “the 1989 Procedures Vol. IV” or “Volume IV, 1989 

edition”. 

EPA420-R-03-010, User’s Guide to MOBILE6.1 and MOBILE6.2: Mobile 

Source Emission Factor Model, August 2003. This is the User’s Guide for 

the official MOBILE6.2.03 on-highway mobile source emission factor model 

and will usually be referred to as the M6.2 (or simply M6) User’s Guide (UG). 

The M6 model in its various versions was developed and published by 

Assessment & Modeling Division (AMD) of the National Vehicle & Fuels 

Emissions Laboratory (NVFEL) in Ann Arbor, Michigan. The NVFEL is part of 

U.S. EPA’s Office of Transportation & Air Quality (OTAQ), formerly the Office 

of Mobile Sources (OMS). 

Technical Guidance on the Use of MOBILE6 for Emission Inventory 

Preparation, August 2004. Hereafter the M6 “Technical Guidance 

[Document]” or “TGD”. The TGD is the primary source of guidance on M6 

inputs and an invaluable adjunct to the M6 User’s Guide. 

U.S. EPA document “Frequently Asked Questions on MOBILE6”, 16 

January 2002. Hereafter [M6] “FAQ”. This document was published along 

with the M6 TGD. 

U.S. EPA memo, “Policy Guidance on the Use of MOBILE6 for SIP 

Development and Transportation Conformity”, dated 18 January 2002, 

from John Seitz, Director of OAQPS, and Margo Oge, Director of OTAQ, to 

Regional Air Division Directors. 

5.3 Ohio’s Alternate Data for MOBILE6.2 

5.3.1 Vehicle Registration Distribution by Age 

Overview: 

The vehicle age distribution determines the fraction of vehicles operating within 

each emissions control requirement standard and the deterioration of the 

emission control technology. 

Emission rates vary widely between new and older vehicles. Thus, even small 

changes in fleet age, particularly for older vehicles, may result in large changes 

in emission totals. 
33

The MOBILE6.2 model requires estimates of a distribution of registered vehicles 

by age and vehicle category for current and future years. MOBILE6.2 default 

values were developed using national level vehicle registration data by age and 

class for July 1, 1996. U.S. EPA developed a methodology to convert the July 1, 

1996 registration profile into a general registration distribution by age and by 

vehicle category for some six composite (gasoline and diesel) vehicle types plus 

motorcycles. To project future changes, U.S. EPA evaluated general sales 

growth and vehicle scrappage trends for the total light-duty vehicle in-use fleet 

and the total heavy duty vehicle in-use fleet, and made minor adjustments, where 

possible, to reflect some of the differences between vehicle categories. 

Description: The MOBILE6.2 model requires estimates of a distribution of 

registered vehicles by age and vehicle category for current and future years. 

Ohio EPA chose to use local vehicle registration data provided by the Ohio 

Bureau of Motor Vehicles (BMV) to LADCO to develop these inputs. 

Method Applicability: This approach is most applicable in areas where there 

are significant differences in the local vehicle fleet age distribution relative to the 

national average. 

Data Sources and Procedures: This approach involves using local vehicle 

registration data. This is typically available at the county level, but may also be 

applied using statewide data from the state motor vehicle registration office. The 

fleet age should be representative of the vehicle fleet over the small urban or 

rural area under question. If the pollutants of concern are ozone precursors. 

Advantages: 

• Uses locally specific registration data, which is likely more representative 

of the local area than the national default. 

• Requires minimal additional resources, particularly if data is readily 

available at the county or local level from the State department of motor 

vehicle registration. 

• Recommended by U.S. EPA and generally is encouraged as a preferred 

approach over the national default approach.

Details: 

Meredith Weatherby of ERG, a subcontractor to LADCO, sent Ohio EPA the files 

that completed the Ohio registration distribution calculations. 

These files contained the registration distribution fractions for each county code 

as well as for the entire state. Each county file was in a format that was directly 
34

useable in the MOBILE6.2 model runs. Additional files contained the fractions as 

well as the numbers of vehicles for each county in a space-delimited file. 

5.3.2 Daily Vehicle Miles Traveled (DVMT) 

Overview: 

Ohio DOT provided the Daily Vehicle Miles Traveled (DVMT) data. DVMT is a 

simple mechanism to measure how much traffic is flowing along a roadway 

during an average 24 hour period. This simple formula multiplies Average Annual 

Daily Traffic (AADT) by the length of the roadway. For example; if a roadway was 

2 miles in length and the AADT was 4000 vehicles per day the DVMT would be 

computed by multiplying 2*4,000 =8,000 or 8,000 DVMT. 

County-by-county DVMT is computed using Ohio DOT roadway information files 

and the annual Highway Performance Monitoring System (HPMS) summary 

reports. DVMT’s are computed for all of the Federal Functional Class (FC) 

categories within each of Ohio’s 88 counties. 

The AADT and roadway length information are very accurate for the state 

highway system (interstate, highway and state routes, ). For roadways that are 

not part of the state highway system, various representative counts were used, 

such as: railroad crossing counts, HPMS sample section counts etc. All traffic 

count data that was not collected during the current year has had a statewide 

growth factor applied that accounts for systematic growth. 

Given the previously mentioned methodologies, the DVMT data is more accurate 

on roads functionally classified as collector or above. 

Functional class categories: 

01 - Rural Interstate 

02 - Rural Principal 

Arterial 

06 - Rural Minor Arterial 

07 - Rural Major Collector

08 - Rural Minor Collector

09 – Rural Local 

11 - Urban Interstate 

12 - Urban Freeway & 

Expressway 

14 - Urban Principal Arterial 

16 - Urban Minor Arterial 

17 - Urban Collector 

19 - Urban Local 

For PDF web based tables of DVMT by county see: 

www.dot.state.oh.us/techservsite/availpro/Road_%20Infor/KDVMT/vmt2002.pdf 
35

Disclaimer by Ohio DOT: 

The above PDF web based tables contain the State of Ohio's adjusted county 

DVMT's and road mileage for the years 1990 - 2004. Please be aware that the 

numbers are estimates only. The factoring process used annual, estimated, and 

statewide ADT (average daily traffic) growth factors, derived from the output of a 

limited number of traffic counting stations around the state. Although the growth 

factors are available by functional class, they are more reliable for major roads 

such as interstates or expressways, which are relatively well-sampled, than for 

local roads or collectors. The numbers also do no allow for periodic, large-scale 

functional reclassification actions which reassign selected roads or road 

segments from one functional class to another. Ohio DOT therefore does not 

warrant the accuracy, completeness, or reliability of these estimates for your 

research. We also do not assume responsibility for any incorrectness that may 

occur. 

5.3.3 Speed Distribution Profile 

Overview: 

According to Mark Byram of Ohio DOT, the speeds that have been used to date 

for air quality analysis were developed by Chuck Gebhardt of Ohio DOT and 

Harry Judson of OHIO EPA for addressing “1 hour standards” conformity rules 

established due to 1990 emissions exceedances. No documentation was found 

in Ohio DOT’s files on the origin of these average speed values or how they were 

estimated. Therefore, staff believed that it was best to use the most recent 

available data to estimate average speeds. Year 2002 speed data was obtained 

from Ohio DOT’s Traffic Monitoring Section’s automatic traffic recorder data and 

summarized for comparison with space mean speeds from Ohio DOT’s travel 

time study done in 2001 (Statewide Travel Time Study, May 2001 by Greg 

Giaimo, Ohio DOT.) These speeds were compared with those developed for 

addressing the one hour standards. The graph below shows the comparison. 

Speeds Comparison

0.0

10.0

20.0

30.0

40.0

50.0

60.0

70.0

80.0

FC01

FC06

FC08

FC11

FC14

FC17

Functional Class

Speed

Average Speed

1990 Analysis

Speeds

2001 Speed Study
36

CAUTION: It should be noted that speeds on facilities falling in any one of the 

federal functional classifications vary greatly between roadways, between hour of 

the day, and day of the week. So these provide only very rough estimates of 

speed and should be used with caution. In addition, it is expected that these 

average statewide speeds are higher than the average speeds in the nonattainment areas because the non-attainment counties tend to be more 

populated and more congested. The document “Highway Vehicle Speed 

Estimation Procedures for Use in Emission Inventories”, September 1991 by Earl 

Ruiter or Cambridge Systematics Inc. is referenced by U.S. EPA’s documented 

procedures for emission inventory preparation. This document suggests post 

processing travel demand model traffic assignment results to estimate average 

speeds. 

The Ohio DOT Modeling & Forecasting Section recommends that Ohio’s travel 

demand forecasting models and Ohio DOT’s conformity analysis methods be 

used to establish the roadway mobile source portion of Ohio’s SIP budget to 

assure consistent methods are used for transportation conformity analysis and 

budgets. 

Research: 

Time Mean Sped-- Summarizing Automatic Traffic Recorder (ATR) Speed 

Data by Functional Class 

Year 2002 speed data for July 2002 was provided by the Traffic Monitoring (TM) 

Section as requested by the Modeling & Forecasting Section (MF). 

The TM section generated reports for each ATR in the state of Ohio, grouped the 

reports by federal functional class and provided the summary reports to the MF 

section. The report includes average speed for each day in July 2002, a 31 day 

period. The data was imported to a spreadsheet where a minimum speed, 

maximum speed and average speed over the 31 day period for all ATR’s located 

on a given functional class was computed, see Table 1 

Table 1 – Comparison of Average Daily speeds from ATR Data with Daily 1990 

Air Quality Speeds 

 Average Min. Avg 

Max. 

Avg. 1990 AQ

 Speed Speed Speed Speeds 

FC01 68.33810 53.9 76.3 57.3

FC02 60.14802 36.2 71.8 45.3

FC06 58.05665 53.5 62.1 39.9

FC07 57.06160 52.9 60.9 35.1

FC08 57.45161 55.2 59.3 30.5

FC09 57.45161 55.2 59.3 28.0

FC11 65.64372 49.7 73.0 46.3
37

FC12 63.89579 50.3 73.2 43.3

FC14 48.97748 31.3 70.1 18.9

FC16 34.52353 30.6 53.2 19.6

FC17 34.52353 30.6 53.2 19.6

FC19 _- _- _- 19.6

The ATR speeds represent our best estimate of “time mean speed”. The speeds 

represent the speed at a point in the middle of a roadway section and does not 

account for slowdowns and delays created by vehicles turning into driveways, 

stopping at intersections, slowing due to incidents, etc. 

Estimating SPACE MEAN SPEED by Functional Class 

Greg Giaimo generated average speed by urban and rural area facility types as 

shown in Table 2 Below. 

Table 2 Speed by Facility Type 

Information from Table 2 was used to estimate space mean speed by functional 

class by assigning federal functional classes as shown in Table 3 with 

consultation with Giaimo. Some speed classes were ignored based on 

Facility 

Type Facility Type Description 

Average 

Speed 

1rural freeway 64

 2rural arterial 53

 3rural 4+ lane collector 42

4rural 2 lane collector, flat 47

5rural 2 lane collector, hilly 44

6rural local, flat 46

7rural local, hilly 37

8rural local, township, flat 40

9rural local, township, hilly 30

11urban freeway 63

 12urban arterial 30

 13urban collector 30

16urban local 25

21cbd freeway 50

 22cbd arterial 23

 23cbd collector 21

26cbd local 12

41rural ramp, off 36

42rural ramp, on 44

51urban ramp, off 32

52urban ramp, on 46
38

recommendation by Giaimo because of the small number miles of those types of 

roadways. 

Table 3 – Functional Class Equivalents 

FT Facility Type 

Speed 

(mph) FunClass Equiv 

1 rural freeway 64 01 Rural Interstate 

2 rural arterial 53 02 06 - Principal & 06Minor Arterial

3 rural 4+ lane collector 42 Ignore 

4 rural 2 lane collector, flat 47 07 08- Major Collector, Minor 

5 rural 2 lane collector, hilly 44 Ignore 

6 rural local, flat 46 09 - local 

7 rural local, hilly 37 ignore 

8 rural local, township, flat 40 09 - local 

9 rural local, township, hilly 30 ignore 

11 urban freeway 63 11Urban Interstate & 12 EXPY 

12 urban arterial 30 14,16 Princ, Major, Minor Art 

13 urban collector 30 17 - Collector 

16 urban local 25 19 - local 

21 cbd freeway 50 11 &12 urban interstate, 50-55mph

22 cbd arterial 23 14,16 - Major&minorArt 

23 cbd collector 21 17 - Collector 

26 cbd local 12 19 – local 

The following formulas were used to estimate the speed: 

Where: 

S=Speed 

FT=Facility Type 

FC=Functional Class 

S(FC01) = S(FT1) 

S(FC02) = S(FT2) 

S(FC06) = S(FT2) 

S(FC07) = AVERAGE(FT3,FT4,FT8) 

S(FC08) = AVERAGE(FT3,FT4,FT8) 

S(FC07) = AVERAGE(FT6,FT8) 

S(FC09) = AVERAGE(FT6,FT8) 

S(FC11) = 0.91*S(FT11)+0.09*S(FT21) 

S(FC12) = 0.91*S(FT11)+0.09*S(FT21) 

S(FC14) = 0.94*S(FT12)+0.06*S(FT22) 

S(FC16) = 0.94*S(FT12)+0.06*S(FT22) 

S(FC17) = 0.94*S(FT13)+0.06*S(FT23) 

S(FC19) = 0.93*S(FT16)+0.07*S(FT26) 
39

Percentage splits for the urban federal functional classes (11trhu 19) were 

derived by summarizing VMT by Facility Types 1 to 26 using the statewide travel 

demand model. The results are shown in Table 4 along with speeds previously 

used for comparison purposes. 

Table 4 – Speed by Federal Functional Class 

1990 

Analysis 

2001 Speed 

Study 

 Speeds Speeds NOACA*

FC01 57.3 64.0 54.7

FC02 45.3 53.0 43.7

FC06 39.9 53.0 38.7

FC07 35.1 43.1 34.2

FC08 30.5 43.1 29.4

FC09 28 43.1- 

FC11 46.3 61.6 44.9

FC12 43.3 61.6 42

FC14 18.9 29.3 18.4

FC16 19.6 29.3 19.6

FC17 19.6 29.2 19

FC19 19.6 23.8- 

* From informal documentation found in files, labeled “Speeds From Bill Davis” 

Figure 1 - Speed Comparison Graphs 

Speeds Comparison

0.0

10.0

20.0

30.0

40.0

50.0

60.0

70.0

80.0

FC01FC02FC06FC07FC08FC09FC11FC12FC14FC16FC17FC19

Functional Class

Speed

Average Speed

1990 Analysis

Speeds

2001 Speed Study

Speeds

2001 Speed

Study Speed

from Bill Davis
40

Speeds Comparison

0

20

40

60

80

100

FC01FC06FC08FC11FC14FC17

RAMPS

Functional Class

Speed

Average Speed

Min. Avg Speed

Max. Avg. Speed

Gebhardt's Speeds

Spd Study Est

Speeds

Spd Study Greg Est

In discussions with James McQuirt, Greg Giaimo and Ansen Wu, it was decided 

that because there is no record of the origin of the speeds established for the 

1990 exceeded emissions/one hour emissions standard, Ohio DOT would be 

best served to use the speeds estimated from the speed study if the origin is well 

documented. 

Conclusion: 

It was decided by mutual agreement among individuals in the Modeling & 

Forecasting Section that these new space mean speed based average speed 

estimates were reproducible and defensible if documented and should therefore 

be the speeds used with HPMS VMT if any year 2002 emissions budget work is 

done using only HPMS VMT. 

Results: 

Speeds used in the speed distribution files from Ohio DOT for the 2002 inventory 

were taken from the 2001 space mean speed study. (See Table 4) 

 

Reference: 

“Draft Technical Memorandum Estimation of Average Speed by Functional 

Class for MOBILE6 Runs,” by Mark Byram, Ohio DOT, Office of Technical 

Services, May 26, 2004 
41

5.4 Ohio’s Non-Alternate (Default) Data for MOBILE6.2 

Per conversation with Mark Janssen at LADCO on 5/14/04, he recommended 

Ohio use the national defaults for the rest of the MOBILE6.2 inputs with the 

exception of providing an RVP value for Ohio. 

5.4.1 Ohio’s Fuel Characteristics 

Background: 

Tom Darlington of Hyper Anemo was contracted by LADCO to evaluate the fuel 

parameters at the county level. In a memo to Mike Koerber, at LADCO he 

states; 

 

“As a part of our project to evaluate the benefits of lower RVP in various 

nonattainment areas in the LADCO 5-state area, we obtained the LADCO 

county-by-county MOBILE6.2 inputs and reviewed the various fuel input 

commands. This memo reviews plots of those inputs, and requests that the 

various states verify these inputs. The inputs that we have selected to review 

have a direct bearing on the baseline RVP of the fuel in each of the counties, and 

thus the benefits of any lower RVP proposal such as 7 RVP.” 

Tom summarized his study saying, “Evaluation of the fuels inputs for the LADCO 

modeling system has shown perhaps a need to reevaluate some of the fuels 

inputs, so that the baseline VOC inventories are correct, and so that the benefits 

of RVP control will be accurately estimated. 

In particular, ethanol market fractions for Michigan, Wisconsin, Indiana, and Ohio 

should be developed by the states or LADCO and utilized. This will also involve a 

change in the July RVP waiver for these states. In addition, areas with RFG 

should be checked to ensure that the appropriate counties have RFG.” 

Process: 

Fuel data parameters were collected from Ohio’s MPOs and analyzed. 

Variations in data suggested the need to determine the source of input values. 

After considerable effort it was determined that the origins of input values were 

unclear. The reevaluation process resulted in establishing the following 

guidelines. 

Guidelines: 

• No MTBE (ether oxygenated fuel) in Ohio 

• 40 percent of Ohio's fuel is ethanol oxygenated with 10 percent oxygen 

content by volume 
42

• Reid Vapor Pressure (RVP) is 9.0 

• RVP waiver switch is 1.0 psi 

5.5 LADCO Data Processing 

LADCO processed Ohio’s data using the Emissions Modeling System 

(EMS-2003). A description of LADCO’s methodology should be 

forthcoming from LADCO in the near future. 
BELOMAR REGIONAL COUNCIL 

Transportation Air Quality Analysis and Technical Documentation 

State Implementation Plan Inventory Mobile Emission Estimates 

For the U.S. EPA Daily Ozone National Ambient Air Quality Standard 

Submitted: April 2012 Revised: August 2012 

Prepared By: 

Bel-O-Mar Regional Council Ohio Department of Transportation 

105 Bridge Street Plaza 1980 West Broad Street 

Wheeling, WV 26003 Columbus, OH 43223 

www.belomar.org http://www.dot.state.oh.us/Divisions/Planning/SPR/
TABLE OF CONTENTS 

Introduction ................................................................................................................................... Page 3 

On Road Mobile Emission Summary ............................................................................................... Page 3 

Latest Planning Assumptions .......................................................................................................... Page 5 

Land Use Data.......................................................................................................................... Page 5 

Travel Modeling.......................................................................................................................... Page 7 

Emission Factor Generation ............................................................................................................ Page 7 

Temperature and Relative Humidity ................................................................................................ Page 9 

Ramp Fraction ................................................................................................................................ Page 9 

Source Type Population ................................................................................................................. Page 10 

Vehicle Age Distribution ............................................................................................................... Page 11 

Road Type Distribution.................................................................................................................. Page 12 

Output Emission Factors............................................................................................................. Page 13 

Post Processing .............................................................................................................................. Page 14 

Appendix A – Interagency Consultation Documentation 

LIST OF TABLES 

Table 1 Belomar Region On-Road Mobile Emissions by State and County (2004, 2009 & 2018).......... Page 4 

Table 2 Belomar Region Land Use Data Used for Traffic Forecasting.................................................. Page 5 

Table 3 MOVES Inputs .................................................................................................................... Page 8 

Table 4 Average Temperature and Relative Humidity Data ................................................................ Page 9 

Table 5 Source Type Population for Year 2005 ................................................................................. Page 10 

Table 6 Vehicle Age Distribution for Belmont County, OH (2005).................................................... Page 11 

Table 7 Road Type Distribution for Ohio-Marshall-Belmont Non-Attainment Area ........... .............. Page 12 

Table 8 MOVES Inputs ................................................................................................................... Page 13 

Table 9 MOVES Inputs ................................................................................................................... Page 13 

Table 10 MOVES Inputs ................................................................................................................. Page 13 

LIST OF FIGURES 

Figure 1 Non-Attainment Area Boundary.................................................................................. Page 3 

Figure 2 Geographic Area Covered by Travel Demand Model and Traffic Zone Structure..................... Page 6 

Figure 3 Emission Calculation Process.................................................................................... Page 14 

SELECTED ABBREVIATIONS & ACRONYMS 

DOT – Department of Transportation EPA – Environmental Protection Agency 

FHWA – Federal Highway Administration; FTA – Federal Transit Administration; 

LRTP – Long Range Transportation Plan MOBILE6 – Mobile Source Emission Factor Model 

MOU – Memorandum of Understanding MPO – Metropolitan Planning Organization 

MVEB – Motor Vehicle Emissions Budget NAAQS – National Ambient Air Quality Standard 

NOx – Nitrogen Oxides 

PM10 – Particulate Matter with an aerodynamic diameter less than 10 microns 

SIP – State Implementation Plan TIP – Transportation Improvement Program 

TAZs – Traffic Analysis Zones TCM – Transportation Control Measure 

TDM – Travel Demand Model TIP – Transportation Improvement Program 

VMT – Vehicle Miles of Travel VOC – Volatile Organic Compounds 
INTRODUCTION 

This memorandum documents the air quality analyses and underlying planning assumptions performed 

by the Ohio Department of Transportation (ODOT), Division of Statewide Planning- Modeling and Forecasting 

Section and the Belomar Regional Council for the Summer Ozone on-road mobile source emission inventories for 

the Wheeling-Bridgeport WV/OH Metropolitan area State Implementation Plan (SIP) in coordination with the 

Ohio Environmental Protection Agency (OEPA) and West Virginia Department of Environmental Protection 

(WVDEP). The Belomar Region is comprised of the counties of Ohio and Marshall in the northern panhandle of 

West Virginia and Belmont in east-central Ohio. On January 5, 2005, the USEPA designated all three counties as 

non-attainment for the Ozone air quality standard. The designation became effective on April 5, 2005; 90 days 

after USEPA published action in the Federal Registry. Figure 1 displays the geographic extent of the Belomar 

region non-attainment area. 

Figure 1 

NON-ATTAINMENT AREA BOUNDARY 

ON ROAD MOBILE EMISSION SUMMARY 

Table 1 presents a summary of the pollutant emissions including Hydrocarbons (HC) and Nitrogen Oxides (NOx 

modeled for each county that make up the Belomar Region. The Model Years for the demonstration includes the 

Base Year 2002, Attainment Year 2004, Interim Year 2009, and Maintenance Year 2018. 
Table 1 

BELOMAR REGION ON-ROAD MOBILE EMISSIONS BY STATE AND COUNTY (2002-04-09-18) 
LATEST PLANNING ASSUMPTIONS 

The summer Ozone inventory runs meet the latest planning assumption requirement. This report presents the 

latest population and land use data available that calibrated the modeling process used to calculate the vehicle 

emissions for the mobile emissions budgets as well as the input values for U.S. EPA’s most recent emissions 

software (MOVES) for this attainment demonstration. (A series of conference calls held during the winter of 

2010/2011 by the Interagency Consultancy Group established that this re-designation effort will require the use of 

MOVES software for all mobile source emission analyses.) 

LAND USE DATA: 

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

units for estimating travel patterns. Socioeconomic data used to forecast these patterns shown in Table 2 include 

household population, school enrollment, vehicle registrations, labor force participation, and employment by 

category and location. Sources for year 2000 data include the 2000 Census (primarily SF1 block data), state 

vehicle registration files, and QCEW/ES202 employment data. All data sources were geocoded to the zone level. 

Future year data for each variable were projected through various methods. More detailed explanation of base 

year and future year data generation for each of the above-mentioned categories of planning data follows. Figure 

2 displays the zones boundaries in the region. 

Table 2 

BELOMAR REGION LAND USE DATA USED FOR TRAFFIC FORECASTING

For most future-year socio-economic data, Belomar staff uses county level projections as prepared by Woods and 

Poole. Allocations of county-level totals by zone are documented in the BOMTS report “BOMTS Traffic Zone 

Data for 2025” with modifications since the date of the report, based on plans submitted for major land 

developments (such as Cabela’s, Center Wheeling, and properties near the Ohio Valley Mall). Woods and 

Poole’s employment projections at the county level are used as control totals for developing TAZ level 

employment by service, retail and manufacturing. The Woods and Poole’s projection at county level is 

disaggregated from a national level employment projection. The national projection is developed using an export 

base approach. Regional differences are considered before county level employment is disaggregated. In 
assigning employment to zones, it is assumed that new sites with developed infrastructure will have a larger share 

of future employment. Given the topography of the region, it is assumed generally that new development will 

mostly occur in one east-west travel corridor (I-70/US40) and one north-south corridor (Ohio Route 7 and 

US250/WV Route 2 along the Ohio River). In Belmont County, however, additional development is expected 

along SR331 and in areas surrounding the urban core. Due to a scarcity of developable land in Ohio County, 

development will occur on sites that are generally flat and can be adequately serviced. In addition, over time, 

generally flat land in the valley will selectively go through planned land use changes to optimize economic 

development. 

Figure 2 

GEOGRAPHIC AREA COVERED BY TRAVEL MODEL AND TRAFFIC ZONE STRUCTURE 

 
TRAVEL MODELING: 

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

future travel patterns. The road networks within them include all planned federal-aid projects as well as any 

regionally significant projects found in the TIP and LRTP expected to be open for traffic by the end of each 

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

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

by zone, with some exceptions, are assumed to change linearly with time between 2000 and the Plan Horizon year 

of 2035. 

The Wheeling area travel demand model network covers about 1500 miles of streets and highways in the 3-county 

area including all collector and arterial streets, and has been validated to observed traffic for year 2000. Land use 

data comes from the Census, ES202 employment reporting, and local vehicle registrations. A trip generation 

model was borrowed from another urban area and adjusted as needed for local land use data. The hourly 

distribution of trips by trip purpose and direction are constrained to match the hourly distribution of traffic counts. 

Trip distribution also begins with a trip-length distribution by purpose borrowed from another urban area and 

adjusted to ensure modeled VMT matched HPMS estimates of VMT within 1% in the model base year of 2000. 

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

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

street network (originating from the U.S. Geological Survey). The modeling software program utilizes hourly 

saturation flow rates that are calculated based on road inventory data, roadway type, and the 2000 version of the 

Highway Capacity Manual (HCM). Coded speeds by street segment are a function of road type and posted speed 

limits and are based on the Ohio statewide travel time study conducted in 2000 (available on the web at 

http://www.dot.state.oh.us/urban/data/statewid/report.doc ) using the “run time” version of speeds without 

intersection delays. The model software program internally estimates additional travel times for vehicles that stop 

for traffic control (stop signs and red lights) based on HCM methods and modeled traffic patterns. The traffic 

assignment RMS (root mean square) error meets FHWA/ODOT standards for all specified volume groups. 

Overall modeled VMT for 2000 was less than 1% different than HPMS estimated VMT. Freeways (federal 

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

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

Marshall counties, WV and Belmont County, OH that reflected the most recent correspondence from the U.S. 

EPA: 

Analysis Year 2002 – Baseline Emissions Analysis Year 2004 – Attainment Year 

Analysis Year 2009 – Interim Year Analysis Year 2018 – Maintenance Year 

EMISSION FACTOR GENERATION 

The MOVES model generated the emission factor files for all analysis years representing the transportation 

improvement programs implemented in the WWW metro area. Table 3 summarizes the settings used in the 

MOVES run specification file and the MOVES County-Data Manager. The subsequent tables provide the specific 

inputs that are not using the MOVES default values. 
Table 3 – MOVES Inputs 

RunSpec Parameter Settings 

MOVES Version MOVES2010A 

Scale Custom Domain 

MOVES Modeling Technique Emission Factor Method 

Rates per Profile (grams/vehicle) 

Rates per Distance (grams/mile) 

Rates per Vehicle (grams/vehicle) 

Time Span Time Aggregation: Hour 

1 Month representing average summer temperatures 

All hours of day selected, 16 speed bins, Weekdays only 

Geographic Bounds Belmont county OH, Ohio and Marshall counties WV 

Vehicles/Equipment All source types, gasoline and diesel 

Road Type All road types including off-network 

Pollutants and Processes Total Gaseous Hydrocarbons, Non-Methane Hydrocarbons, Volatile 

Organic Compounds, NOx, NO, NO2, 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. 

Advance Performance None 

County Data Manager Sources 

Source Type Population Combination of local and default data 

Local data (OH&WV) from motor vehicle registration 

Default data used for source types 41, 51, 54, 61, and 62 

Future year growth rate 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 

Metereology 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 WVDOH county summary VMT categorized by 

federal functional classes 

Age Distribution Combination of local and default data. 

Local data (2010) ODOT from motor vehicle registration 

Default data used for source types 41, 51, 54, 61, and 62 

The same age distribution will be used for all analysis years 

Average Speed Distribution Default 

Alternative Fuel Type Default 
TEMPERATURE AND RELATIVE HUMIDITY 

The single season approach for temperature and relative humidity uses weather data collected by the National 

Oceanic and Atmospheric Administration (NOAA) National Climatic Data Center (NCDC). The data used in this 

report, taken from the Wheeling Airport collection center, is representative of 12 months in 2009. Data entered 

into a spreadsheet provided by U.S. EPA converted the Mobile6 to get the correct data for the MOVES model. 

Table 4 below contains the average annual hourly temperatures and relative humidity distribution profiles used for 

the Belomar region. 

Table 4 

AVERAGE TEMPERATURE AND RELATIVE HUMIDITY DATA 

Time of Day Average Temperature Average Relative Humidity (%)

Midnight 47.2 79.7

1 AM 46.1 67.1

2 AM 45.2 80.7

3 AM 44.6 82.9

4 AM 44.1 83.8

5 AM 43.6 84.1

6 AM 43.1 82.6

7 AM 43.5 79.6

8 AM 45.9 74.8

9 AM 49.6 70.1

10 AM 53.5 65.7

11 AM 56.8 62.0

12 PM 59.7 59.8

1 PM 61.3 58.2

2 PM 61.9 57.4

3 PM 62.0 57.3

4 PM 61.6 58.3

5 PM 60.5 61.2

6 PM 58.6 65.3

7 PM 56.2 69.2

8 PM 53.7 66.1

9 PM 51.6 74.3

10 PM 50.1 75.7

11 PM 48.6 78.1

RAMP FRACTION 

The Vehicles Hour of Travel (VHT) fractions from the travel demand model were used to derive the Ramp 

Fraction values needed for the MOVES model procedures (approximately 4% in Belmont county Ohio, 8% in 

Ohio county West Virginia, and 3% in Marshall county West Virginia). 
SOURCE TYPE POPULATION 

A combination of local and MOVES default data is the Source Type Population for vehicle classifications. The 

MOVES default values provided the data for vehicle Source Types 51, 52, 53, 61, and 62 while local data from 

Ohio and West Virginia motor vehicle registrations accounted for all other Source Type Populations needed to 

run the MOVES model. Table 5 shows the Source Type Population identifications, the corresponding Source 

Type Name, and the number of vehicles analyzed for Belmont County, OH and Ohio/Marshall County, WV 

combined. 

Table 5 

SOURCE TYPE POPULATION FOR YEAR 2005 

year Source Type Belmont # Marshall co # Ohio co #

2005 11 MotorCycle 4724 937 1149

2005 21 Passenger Car 48706 9650 17852

2005 31 Passenger Truck   22592 9946 14061

2005 32 Light Commercial Truck 602 1755 2285

2005 41 Intercity Bus 58 5 16

2005 42 Transit Bus   2 3 9

2005 43 School Bus   127 99 51

2005 51 Refuse truck   35 8 14

2005 52 Single Unit Short‐haul Truck   14 461 818

2005 53 Single Unit Long‐haul Truck   55 53 93

2005 54 Motor Home   165 21 48

2005 61 Combination Short‐haul Truck 786 78 245

2005 62 Combination Long‐haul Truck 984 86 272

 
VEHICLE AGE DISTRIBUTION 

A grouping of data from Ohio and West Virginia sources along with the MOVES model defaults make up the 

Vehicle Age Distribution. MOVES default values included Vehicle Type ID 41, 42, 51, 52, 53, 61, and 62. Local 

data from Ohio and West Virginia motor vehicle registrations accounted for all other Vehicle Type ID. Table 6 

shows a sample Vehicle Age Distribution By Source Type for Belmont County, OH in 2005. 

Table 6 

VEHICLE AGE DISTRIBUTION BY SOURCE TYPE FOR BELMONT COUNTY, OHIO IN 2005

yearid ageid 11 21 31 32 41 42 43 51 52 53 54 61 62

2005 0 0.003 0.004 0.006 0.010 0.000 0.000 0.023 0.000 0.000 0.000 0.003 0.003 0.011 

2005 1 0.025 0.020 0.022 0.028 0.053 0.000 0.031 0.000 0.000 0.000 0.018 0.012 0.033 

2005 2 0.052 0.033 0.047 0.069 0.026 0.000 0.047 0.000 0.000 0.000 0.033 0.024 0.018 

2005 3 0.068 0.039 0.051 0.066 0.026 0.000 0.055 0.286 0.286 0.286 0.039 0.028 0.096 

2005 4 0.085 0.042 0.061 0.068 0.316 0.000 0.047 0.000 0.000 0.000 0.030 0.037 0.079 

2005 5 0.083 0.048 0.076 0.025 0.079 0.000 0.016 0.000 0.000 0.000 0.037 0.049 0.064 

2005 6 0.068 0.047 0.066 0.015 0.053 0.000 0.063 0.000 0.000 0.000 0.041 0.047 0.030 

2005 7 0.079 0.048 0.065 0.045 0.000 0.000 0.070 0.214 0.214 0.214 0.028 0.047 0.038 

2005 8 0.064 0.057 0.068 0.048 0.079 0.000 0.070 0.000 0.000 0.000 0.033 0.043 0.033 

2005 9 0.051 0.054 0.056 0.035 0.053 0.000 0.070 0.000 0.000 0.000 0.034 0.043 0.052 

2005 10 0.042 0.062 0.063 0.069 0.026 0.000 0.063 0.000 0.000 0.000 0.043 0.057 0.085 

2005 11 0.032 0.060 0.056 0.041 0.105 0.000 0.086 0.000 0.000 0.000 0.043 0.051 0.083 

2005 12 0.027 0.056 0.054 0.055 0.053 0.000 0.141 0.000 0.000 0.000 0.035 0.045 0.080 

2005 13 0.020 0.055 0.045 0.030 0.000 0.000 0.078 0.000 0.000 0.000 0.024 0.045 0.041 

2005 14 0.020 0.050 0.041 0.031 0.000 0.000 0.008 0.071 0.071 0.071 0.020 0.038 0.053 

2005 15 0.014 0.051 0.048 0.055 0.026 0.000 0.047 0.071 0.071 0.071 0.032 0.048 0.053 

2005 16 0.015 0.043 0.043 0.040 0.000 0.500 0.000 0.071 0.071 0.071 0.027 0.051 0.027 

2005 17 0.012 0.038 0.031 0.028 0.000 0.000 0.008 0.071 0.071 0.071 0.025 0.035 0.011 

2005 18 0.012 0.034 0.020 0.036 0.026 0.000 0.000 0.000 0.000 0.000 0.028 0.030 0.029 

2005 19 0.009 0.031 0.017 0.031 0.000 0.500 0.031 0.000 0.000 0.000 0.020 0.033 0.005 

2005 20 0.007 0.022 0.013 0.028 0.026 0.000 0.000 0.071 0.071 0.071 0.014 0.028 0.006 

2005 21 0.008 0.019 0.012 0.025 0.000 0.000 0.023 0.000 0.000 0.000 0.029 0.029 0.017 

2005 22 0.006 0.015 0.009 0.033 0.000 0.000 0.000 0.071 0.071 0.071 0.024 0.032 0.015 

2005 23 0.010 0.010 0.008 0.018 0.000 0.000 0.016 0.000 0.000 0.000 0.025 0.021 0.015 

2005 24 0.018 0.007 0.006 0.018 0.027 0.000 0.008 0.072 0.072 0.072 0.024 0.023 0.005 

2005 25 0.019 0.006 0.005 0.008 0.000 0.000 0.000 0.000 0.000 0.000 0.022 0.016 0.006 

2005 26 0.014 0.006 0.004 0.010 0.000 0.000 0.000 0.000 0.000 0.000 0.022 0.014 0.008 

2005 27 0.016 0.002 0.002 0.013 0.000 0.000 0.000 0.000 0.000 0.000 0.017 0.008 0.003 

2005 28 0.017 0.001 0.001 0.002 0.026 0.000 0.000 0.000 0.000 0.000 0.013 0.007 0.000 

2005 29 0.018 0.002 0.001 0.007 0.000 0.000 0.000 0.000 0.000 0.000 0.014 0.007 0.000 

2005 30 0.088 0.038 0.006 0.014 0.000 0.000 0.000 0.000 0.000 0.000 0.201 0.054 0.006 
ROAD TYPE DISTRIBUTION 

The ODOT and WV Division of Highway county summary Vehicle Miles Traveled (VMT) data categorized by 

federal functional class for the three county non-attainment areas is the basis for Road Type Distribution Fraction. 

Table 7 illustrates Road Type Distribution. 

Table 7 

ROAD TYPE DISTRIBUTION FOR THE BELOMAR REGION 

sourceTypeID roadTypeID roadTypeVMTFraction sourceTypeID roadTypeID roadTypeVMTFraction 

11 1 0 51 1 0

11 2 0.25 51 2 0.25

11 3 0.24 51 3 0.24

11 4 0.18 51 4 0.18

11 5 0.33 51 5 0.33

21 1 0 52 1 0

21 2 0.25 52 2 0.25

21 3 0.24 52 3 0.24

21 4 0.18 52 4 0.18

21 5 0.33 52 5 0.33

31 1 0 53 1 0

31 2 0.25 53 2 0.25

31 3 0.24 53 3 0.24

31 4 0.18 53 4 0.18

31 5 0.33 53 5 0.33

32 1 0 54 1 0

32 2 0.25 54 2 0.25

32 3 0.24 54 3 0.24

32 4 0.18 54 4 0.18

32 5 0.33 54 5 0.33

41 1 0 61 1 0

41 2 0.25 61 2 0.25

41 3 0.24 61 3 0.24

41 4 0.18 61 4 0.18

41 5 0.33 61 5 0.33

42 1 0 62 1 0

42 2 0.25 62 2 0.25

42 3 0.24 62 3 0.24

42 4 0.18 62 4 0.18

42 5 0.33 62 5 0.33

43 1 0 roadTypeID roadDesc 

43 2 0.25 2 Rural Restricted Access 

43 3 0.24 3 

Rural Unrestricted 

Access 

43 4 0.18 4 Urban Restricted Access 

43 5 0.33 5 

Urban Unrestricted 

Access 
OUTPUT EMISSION FACTORS 

Table 8 shows the first record in a MOVES sample output (rate per distance) emission file for year 2005 

with I/M programs. For any given month, day of week, hour of the day, pollutant, and source type; the 

rate per distance varies by road type and speed bin. Rates per distance emissions are applied to link and 

intrazonal VMT. 

Table 8 – Sample Emission File (Rate per Distance) for year 2005 

Heading: MOVESScenarioID MOVESRunID yearID monthID dayID hourID 

Record: 2005 7 5 1 

Heading: linkID pollutantID processID sourceTypeID SCC fuelTypeID 

Record: 87 0 1 0 

Heading: modelYearID roadTypeID avgSpeedBinID temperature relHumidity ratePerDistance 

Record: 0 2 1 6.90740776 

Table 9 shows the first record in a MOVES sample output (rate per vehicle) emission file for year 2005 

with I/M programs. The rate per vehicle varies for any combinations of month, day of week, hour of the 

day, pollutant, and process. Rates per vehicle emissions are applied to the vehicle source type 

population. 

Table 9 – Sample Emission File (Rate per Vehicle) for year 2005 

Heading: MOVESScenarioID MOVESRunID yearID monthID dayID 

Record: 2005 7 5 

Heading: hourID zoneID pollutantID processID sourceTypeID 

Record: 1 87 1 

Heading: SCC fuelTypeID modelYearID temperature ratePerVehicle 

Record: 0 0 0.27257887 

Table 10 shows the first record in a MOVES sample output (rate per profile) emission file for year 2005 

with I/M programs. The rate per vehicle varies for any combinations of month, day of week, hour of the 

day, pollutant, and process. Rates per profile emissions are applied to the vehicle souce type population. 

Table 10 – Sample Emission File (Rate per Profile) for year 2005 

Heading: MOVESScenarioID MOVESRunID yearID monthID dayID 

Record: 2005 0 5 

Heading: hourID zoneID pollutantID processID sourceTypeID 

Record: 1 87 0 1 

Heading: SCC fuelTypeID modelYearID temperature ratePerVehicle 

Record: 0 0 0.01774139 
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_jan_2012
APPENDIX A 

INTERAGENCY CONSULTATION DOCUMENTATION 
Public Notice 

Ohio Environmental Protection Agency 

Redesignation and Maintenance Plan for the Ohio Portion of the Wheeling, WVOH, Area 

Belmont County 

Notice is hereby given that the Director of the Ohio Environmental Protection Agency, 

(Ohio EPA) is requesting that the United States Environmental Protection Agency (U.S. 

EPA) revise the current maintenance plan for the Ohio portion of the Wheeling Area, 

(Belmont County), with respect to the 1997 eight-hour ozone national ambient air quality 

standard (NAAQS). Ohio EPA submitted a redesignation request and maintenance plan 

for this area on June 20, 2006. Subsequently, U.S. EPA approved this requests on May 

16, 2007. Air quality monitoring data collected in the region demonstrated attainment of 

the NAAQS and there was evidence that the improved air quality is due to permanent, 

enforceable emission reductions. In addition, existing requirements are sufficient to 

maintain the 1997 eight-hour ozone standard in this area throughout the maintenance 

period. 

Ohio EPA is now requesting a revision to the maintenance plan to update mobile 

emission projections and conformity budgets based on emission rates generated from 

U.S. EPA’s latest mobile emissions model, the Motor Vehicle Emission Simulation 

(MOVES) 2010. In December 2009, MOVES replaced MOBILE6.2 as the U.S. EPA’s 

official mobile emission model. 

These actions must be noticed to allow public comment and to satisfy U.S. EPA 

requirements for public involvement in SIP related activities. This notice addresses Ohio 

EPA’s reliance on the emission projections as evidence of attainment and maintenance 

and the commitment to institute contingency measures if ambient exceedances or 

violations trigger the contingency plan requirements. Written comments will be received 

on or before November 20, 2012 at the following address:

E-mail: erica.fetty@epa.state.oh.us

Mailing address: Erica Fetty 

Ohio Environmental Protection Agency, DAPC 

Lazarus Government Center 

P.O. Box 1049 

Columbus, Ohio 43216-1049 

Phone: (614) 644-2310 

Pursuant to Section 119.03 of the Ohio Revised Code, a public hearing on this 

redesignation request will be conducted as follows: Tuesday, November 20, 2012 at 

3:00P.M., at Bellaire Public Library located at 330 32nd Street, Bellaire, Ohio. 

All interested persons are entitled to attend or be represented at the hearings and give 
written or oral comments on these changes. All oral comments presented at the 

hearing, and all written statements submitted at the hearing or to the above address by 

the close of business on November 20, 2012 will be considered by Ohio EPA prior to 

final action on this redesignation. Written statements submitted after November 20, 

2012 may be considered as time and circumstances permit, but will not be part of the 

official record of the hearing. 

This redesignation and maintenance request is available on Ohio EPA DAPC’s Web 

page for electronic downloading at: http://www.epa.ohio.gov/dapc/SIP/1997.aspx. 

Questions regarding accessing the web site should be directed to Arunee Niamlarb at 

614-728-1342; other questions or comments about this document should be directed to 

either Erica Fetty, (614)-644-2310, Erica.Fetty@epa.state.oh.us or Jennifer Dines at 

(614) 644-3696, Jennifer.Dines@epa.state.oh.us or mailed to Erica Fetty or Jennifer 

Dines at the above address. 
( 

BEFORE THE OHIO EPA 

IN RE: 

REDESIGNATION AND 

MAINTENANCE PLAN FOR OZONE 

BASIC NONATTAINMENT AREA, 

BELMONT COUNTY. 

Taken before Michelle K. Douridas, 

a Registered Professional Reporter and 

Notary Public in and for the State of Ohio, 

at the Bellaire Public Library, 330 32nd Street, 

Bellaire, Ohio, commencing on Tuesday, November 

20th, 2012, at 3:00p.m. 

MODERATOR MARY McCARRON 

Main Office 

8036 Smoke Road 

Pataskala, Ohio 43062 

(740) 927-3338 

(800) 852-6163 

Fax (740) 927-3436 

www.FraleyCooper.com 

NOV 2/2012 

Columbus, Ohio 

(614) 228-0018 

Newark, Ohio 

(740) 345-8556 
(> 

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P R 0 C E E D I N G S 

MODERATOR McCARRON: My name is Mary 

McCarron. I am the Public Involvement Manager 

for Ohio EPA's Public Interest Center. 

presiding over today's public hearing. 

I will be 

The purpose of the hearing today is to 

obtain comments from any interested person 

regarding Ohio EPA's proposed action. 

The State of Ohio is requesting that 

U.S. EPA revise the current maintenance plan for 

the Ohio portion of the Wheeling Area, Belmont 

County, with respect to the 1997 eight-hour ozone 

national ambient air quality standard. 

Ohio EPA is now requesting a revision to 

the maintenance plan to update mobile emission 

projections and conformity budgets based on 

emission rates generated from U.S. EPA's latest 

mobile emissions model, the Motor Vehicle 

Emission Simulation 2010. In December 2009, 

MOVES replaced MOBILE6.2 as the U.S. EPA's 

official emission factor model. 

All interested persons are entitled to 

attend or be represented and to present oral 

Fraley, Cooper & Associates (614) 228-0018 (800) 852-6163 (740) 345-8556 
Page 3 

and/or written comments concerning the proposed 

2 action. All written and oral comments received 

3 as part of the official record will be considered 

4 by the Director of Ohio EPA. 

5 To be included in the official record, 

6 written comments must be received by Ohio EPA by 

7 close of business today, November 20th, 2012. 

8 These comments may be filed with me today or 

9 e-mailed to erica.fetty@epa.ohio.gov. 

10 All written comments submitted for the 

11 record receive the same consideration as oral 

12 testimony given today. 

I 13 ' Written statements submitted after today 

14 may be considered as time and circumstances 

15 permit, but will not be part of the official 

16 record of the hearing. 

17 At this time there is nobody present to 

18 provide testimony, so we will go off the record 

19 for 30 minutes. 

20 (Short break in proceedings.) 

21 MODERATOR McCARRON: Seeing no requests 

22 for testimony, the hearing is now adjourned. 

23 Thereupon, at 3:30 p.m. on Tuesday, 

24 November 20th, 2012, the hearing was concluded. 

Fraley, Cooper & Associates (614) 228-0018 (800) 852-6163 (740) 345-8556 
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C E R T I F I C A T E 

STATE OF OHIO 

SS: 

COUNTY OF LICKING 

I, Michelle K. Douridas, a Registered 

Professional Reporter and Notary Public in and 

for the State of Ohio, duly commissioned and 

qualified, do hereby certify that this hearing 

was by me reduced to stenotype; that the 

foregoing is a true and correct transcript of the 

hearing; that the hearing was taken at the time 

and place in the caption specified and was 

completed without adjournment; and that I am in 

no way related to or employed by any attorney or 

party hereto, or financially interested in the 

action, and I am not, nor is the court reporting 

firm with which I am affiliated, under a contract 

as defined in Civil Rule 28(D). 

IN WITNESS WHEREOF, I have hereunto set 

my hand and affixed my seal of office at 

Pataskala, Ohio, on this 26th day of November, 

2012. 

My Commission Expires: 

M CHELLE K. DOURIDAS, RPR 

NOTARY PUBLIC-STATE OF OHIO 

July 16th, 2013. :·' 'i 

'i )' ··., ·: 

' ( 

Fraley, Cooper & Associates (614) 228-0018 (800) 852-6163 (740) 345-8556 
Hearing held on November 20, 2012 

Page 1 

A current 2: II 4:9 3:4,6 4:2,5,12 represented 2:24 WITNESS 4: II 

action 2:9 3:2 Involvement 2:4 4:16 requesting 2: I 0 written 3:1,2,6 

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Area 1 :4 2:12 Library 1:13 permit3:15 82:1 2010 2:20 

attend 2:24 E LICK1NG4:3 person 2:8 same 3:11 20121:15 3:7,24 

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based 2:17 2:20,22 2:11,16 portion 2: 12 Short3:20 28(D)4:10 

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before 1:1,10 employed 4:8 Mary 1:18 2:3 3:17 specified 4:7 3 

Bellaire 1:13,14 entitled 2:23 may 3:8,14 presiding 2:6 SS4:2 3:00 1:15 

Belmont I :5 2:12 EPA 1:1 2:11,15 McCARRON proceedings 3:20 standard2:14 3:30 3:23 

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budgets 2:17 EPA's 2:5,9,18 Michelle 1: 10 1:114:4 4:2,5 32nd 1:13 

business 3:7 2:21 4:4,15 projections 2:17 statements 3: 13 3301:13 

erica.fetty@ep ... minutes 3:19 proposed 2:9 3: 1 stenotype 4:6 

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interested 2:8,23 2:5,9,10,12,15 reporting 4:9 4:11 

Fraley, Cooper & Associates (614) 228-0018 (800) 852-6163 (740) 345-8556