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

### This page left intentionally blanki 

## 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 ........................................................................................ 2 4 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 NO x sources...................................................................................................... 30

Chapter Seven Public participation .......................................................................................................... ............ 32

Chapter Eight Conclusions ................................................................................................................... ............. 33ii 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 NO x Emission Inventory Belmont Co. Ohio ......................................................... 19 Table 12 NO x Emission Inventory Marshall Co and Ohio Co. WV ..................................... 20 Table 13 Wheeling, WV: NO x 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 Documentationiii 

### This page left intentionally blank1 

## 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 ai r 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 nonatta inment areas for t he eight-hour ozone standard. Since that time, U.S. EPA has recla ssified nine of the 134 original nonattainment areas to the next lower classification. Sect ion 107(d)(3)(E) of the C AA allows states to request nonattainment areas be redesignated to attainment providing ce rtain criteria are met. The following are the criteria that must be met in order for an ar ea to be redesignated from nonattainment to attainment:

i) A determination that the area has a ttained 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 qua lity is due to permanent and enforceable reductions in emissions resulting from implementation of the SIP and other f ederal 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 Count ies 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-eval uation, the Wheeling, WV-OH: Belmont County area was designated as Un classifiable/Attainment for the one-hour ozone standard pursuant to the CAA and therefor e, has not previously been s ubject 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 devel opment of a plan to reduce volatile organic compounds2 

### (VOCs) and oxides of nitrogen (NO x 

### ) emissions and a demonstration that the area will meet the federal eight-hour air qualit y 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 oz one standard. In addition, the three-year period 2003 – 2005 cont inues to demonstrate attainment of the eight-hour standard.

Geographical Description Belmont County is located in eas tern 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) year s, 2002 through 2004, demons trates that the air quality has met the NAAQS for ozone in this basic nonattainment area. The most recent three-year period, 2003 thr ough 2005, continues to demonstrate attainment of the standard. The NAAQS attainment, accom panied by decreases in emission levels discussed in Chapter four, supports a redesignat ion 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 gui dance in a document entitled Procedures for Processing Requests to Redesignate Areas to Attainment (redesignation guidance), issued September 4, 1992, to Regional Air Directo rs. This request for redesignation and maintenance plan is based on t he redesignation guidance, supplemented with additional guidance received from staff of U.S. EPA Region V.

Below is a summary of each redesignation crit erion as it applies to Wheeling, WV-OH: Belmont County.

i.) Attainment of the standard: There are two components involved in ma king this demonstration. The first component relies on ambient air quality data. The data that are used to demonstrate attainment should be the pr oduct of ambient monitoring that is representative of the area of highest concentration. The data should be collected and quality-assured in accor dance with 40 CFR 58 and recorded in the Aerometric Information Retrieval Syst em (AIRS) in order for it to be available to the public for review.

The second component relies upon s upplemental U.S. EPA-approved air quality modeling. The s upplemental modeling is not required for ozone nonattainment areas seeking redesignat ion. 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 mo re 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 t he area. Ohio’s SIP was approved on May 9, 1994 (59FR23799) March 23, 1995 (60FR15235) and includes Wheeling, WV-OH: Be lmont County. Chapter five discusses this requirement in more detail and provi des the attainment demonstration.

iii.) Permanent and enforceable im provement in air quality: The state must be able to reasonably a ttribute the improvement in air quality to emission reductions which are pe rmanent and enforceabl e. 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 Count y was not designated nonattainment for ozone as part of the 1990 CAA Amendments re -evaluation. As a result, Ohio has not adopted or implemented cont rol measures beyond the federal measures, the initial 1979 statewide rules and those 1994 and 1995 rules which applied to “rural” attainment areas . Chapters four an d five discuss this requirement in more detail and prov ide the attainment demonstration.

iv.) Section 110 and Part D requirements: For purposes of redesignation, a state mu st meet all requir ements of Section 110 and part D that were applicable prio r to submittal of the complete redesignation request.

Part D consists of general requirem ents applicable to all areas which are designated nonattainment based on a violation of the NAAQS.

i.) Section 172(c) requirements This section contains general r equirements for nonattainment plans. The requirements for reasonable further progress, identification of certain emissions increases, and other measures needed for attainment will not apply for redesi gnations because they only have meaning for areas not attaining the standard. The r equirements 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 mu st 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 rele vant 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 mini mum, the contingency measures must include a requirement that the state will implement all measures contained in the nonattainment SIP prior to redesignation.

States seeking redesignat ion of a nonattainment ar ea 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 m onitors used for measuring ozone concentrations for Belmont County in 2002 thru 2004 are located in Ohio County in West Virginia. The monito rs are operated by t he West Virginia Department of Environmental Protection (DEP), Division of Air Quality (DAQ), Northern Panhandle Regional Office. Figur e 2 shows the location of the monitor locations for 2003 thru 2005. See Requirement 3 of 4 Demonstration section in this chapter for an expl anation 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 acco rdance 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 show n 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 ther efore 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 dow nwind environs, are below 85 parts per billion (ppb). This showing must rely on three (3) co mplete, consecutive cal endar years of quality assured data8 

### 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 oz one monitoring data are required to demonstrate attainment at a monitori ng site. The eight-hour primary and secondary ozone ambient air quality st andards are met at an ambient air quality monitoring site when the three- year average of t he annual fourthhighest daily maximum eight-hour aver age 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 ca rried in the computations. Because the third decimal digit, in ppm , is rounded, 0.084 ppm is th e largest concentration that is less than or equal to 0.08 ppm. Therefore, for the purposes of this request, the eight-hour standard is cons idered 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 dat a handling procedures are applied on an individual basis at each monitor in t he area. An area is in compliance with the eight-hour ozone NAAQS i f, 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 concen tration is also called the site's design value. Tabl e 1 shows the monitoring data for 2002 – 2004 and Table 2 shows the monito ring data for 2003-2005 at the nonattainment area sites and was retr ieved from the U.S. EPA AQS.

Demonstration : A listing of the four (4) highest r eadings from 2002 through 2004 is shown in Table 1 and readings from 2003-2005 are show n 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

1 s t 2 n d 3 r d 4 th 2002-2004 AVERAGE SITE ID COUNTY ADDRESS YEAR %OBS 8-HR 8-HR 8-HR 8-HR 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 ppm9 

### 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

1 s t 2 n d 3 r d 4 th 2003-2005 AVERAGE SITE ID COUNTY ADDRESS YEAR %OBS 8-HR 8-HR 8-HR 8-HR 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 WA TER 2005 100 .097 .097 .091 .089 0.76 ppm



### Seasonal ozone monitoring at Whee ling, 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 Wheeli ng monitoring site, number 54-069- 0010 was installed in late 2004. This monitor is located approximately three tenths of a mile sout h 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 4 th 

### highest eight-hour ozone average of 0.082 ppm in 2004 fo r the three year average ozone concentration to violate the N AAQS for the peri od 2002-2004. An examination of the dat a from the other ozone monitoring sites also demonstrates that none of these lo cations exceeded an ozone average of 0.082 ppm.

The area's design value has trended dow nward as emissions have declined due to such factors as cleaner autom obiles and fuels both regionally and locally. U.S. EPA’s rule to control nitrogen oxides from specific source categories (40 CFR Part s 51, 72, 75 and 96, published on October 17, 1998 and referred to as the NO x 

### SIP Call) has significantly reduced emissions from large electric generating units (EGUs), industrial boilers, and cement kilns. Ohio's NO x 

### 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 Intersta te 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 monitori ng 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 s ubmittal of a compr ehensive inventory of ozone precursor emissions (VOC and NO x 

### ) representative of t he year when the area achieves attainment of the oz one air quality standard. Ohio also must demonstrate that the improvement in air qua lity between the year that violat ions occurred and the year that attainment was achieved is based on pe rmanent and enforceable emission reductions. Other emissions inventory related requirem ents include a projection of the emission inventory to a year at least 10 years follo wing redesignation; a demonstration that the projected level of emi ssions 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 pr ecursors of ozone completed for the base year.

Background : The point source data are taken fr om 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-O H: Belmont County.

As part of the NO x 

### SIP Call, many states, incl uding 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 NO x 

### emissions. These emissions, capped by t he state rule, should remain at or near this level through the maintenance period covered by this request.

Periodic inventories, which include emissi ons from all sectors - mobile, area, non-road, and point sources - are prepared every three (3) years.

Demonstration : While ozone and its precursors are transpor ted 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 NO x 

### SIP Call. Other sectors of the inventory also impact ozone formati on, 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 emi ssion inventory to a year at leas t 10 years following redesignation.

Background : Ohio EPA prepared a comprehensive inv entory for Belmont County, including area, mobile, and point sources fo r precursors of ozone (VOCs and NO x 

### ) 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 Directo rs Consortium (LADCO) and have been processed to develop summer day emi ssions for use in the air quality analyses. These processed modeling inv entories have been identified as the correct iteration of the inventory for use in the redesignation. In this document, references to LADCO in clude 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 database 1



### .

• Biogenic emissions are not included in these summaries.

• Non-road emissions were generated using U.S. EPA’s National Mobile Inventory Model (NMIM) 2002 applicat ion. To address concerns about the accuracy of some of t he categories in U.S. EPA’s non-road emissions model, LADCO contract ed 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 mo del. Emissions were estimated for aircraft, commercial marine ve ssels and railroads. Recreational motorboat population and spatial surrogates (used to assign emissions to each county) were significantly updated. The populations for the construction equi pment 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/acidrain13 

### Demonstration :

On-Road Emission Estimations In coordination with the Belmon t, Ohio, Marshall Regional Council Metropolitan Planning Organization (Bel -O-Mar) and the West Virginia Department of Transportation (WVD OT), the Ohio Department of Transportation (ODOT) utiliz es a regional travel demand forecast model to simulate traffic in the area and to fore cast traffic flows for given growth expectations. The model is primarily used as a long range planning tool to evaluate the transportation system includi ng 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 tota l emissions of pollution caused by vehicles in the area. The travel dem and forecasting model is used to predict the total daily vehicle miles trav eled (VMT) and an EPA co mputer 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 emissi ons per mile (grams/mile) for ozone precursors, NO x 

### and VOC. The MOVES2010 model incl udes 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 her e. The source types are traveling on road types (MOVES2010 road types are Rural Restricted Access, Rural Unrestricted Access, Urban Restrict ed Access, and Urban Unrestricted Access). The vehicle speeds also a ffect the emission factor values. Meteorological conditions such as air temperature and humidity has a significant effect on emission factor s. Emission factors produced by MOVES2010 can also include the effect of emission reduction strategies such as vehicle inspection and maint enance programs, regul ation of fuels, etc. These MOVES2010 inputs are estima ted using the best available data. These inputs are reviewed and agreed to by EPA and transportation agencies in a formal interagency consultati on 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, devel oped by ODOT, is to aggregate the emission rates by two source types (cars & trucks), then applying VMT and source type population, thereby reducing t he intensive processe s. In the first step emission factors are broadly classi fied into total vehicles, cars and trucks by pollutant, by average speed, road type and hour of day. Then the hourly link volumes generated from trav el demand model are combined with emission factors for each network lin k 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 popul ation. Intrazonal emissions are computed using a separate method to acc ount for those trips that use local roads to travel within a zone. Intr azonal VMT is combined with corresponding emission factors to get intrazonal emi ssions. Total emissions are sum of onroad vehicle emissions, vehicle-based emissions and intrazonal emissions. Automated programs, using FORTRA N 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 fo rmats and MOVES generated emission factors

Best Available Data Most current vehicle age distribution dat a, temperature data, fuel properties data, and source type distribution data provided by ODOT’s ATRs and WIMs, NOAA, ODPS, and Ohio EPA were us ed by the ODOT for generating emission factors. Like wise, the most current transportation planning data available from Bel-O-Mar and most cu rrent ODOT count data were used for the emissions estimates.

Analysis Years Analysis years for this re-designat ion request include 2002, 2004, 2009, and 2018 to meet the requirements specif ied by the CAA and EPA. The travel demand model presents the transportati on system conditions for each of these years. Model runs for each fu ture 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 explic itly modeled in a travel demand model. These local r oads are represented as fictitious roadways called centroid connectors. Local road VMT is included in the ODOT post process by including the tra ffic loaded on centroid connectors. In addition, some local road traffic is capt ured 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 result s 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 0.6916 

### Table 6 Combined VOC and NO x 

### 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

T OTAL 2.77

NO x 

### Belmont County, OH NO x 

### 4.14 Marshall County, WV NO x 

### 0.69 Ohio County, WV NO x 

### 1.46

T OTAL 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 NO x 

### (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 Planni ng 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 NO x 

### . These correspond to a 25 percent increase from the 2018 on-r oad emissions for both VOC and NO x 

### . Appendix C contains data tables and graphs of these emissions.

All methodologies, latest planning assump tions and the safety margins were determined through the interagency cons ultation process described in the17 

### Transportation Conformity Memorandum of Understanding (MOU) for Bel-OMar. Requirement 3 of 5 : A demonstration that the project ed 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 redesignati on 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 we re 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 file s 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 redesignati on 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. T herefore, Ohio EPA performed an initial comparison of t he inventories for the base year and maintenance years. Mobile source em ission inventories are described in Appendix B. In addition to the LADCO estimates, point source emissions were projected based upon the statewide EGU NO x 

### budgets from the Ohio NO x 

### 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 Associ ation of the Southeast (VISTAS), a federally recognized regional planning organization. The following tables include sectors Elec trical 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 Planni ng 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 9.3519 

### 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 Margin Maintenance

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 NO x 

### 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 budget20 

### Table12 Combined Marshall and Ohio County, WV NO x 

### 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: NO x 

### 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 NO x 

### TOTAL 220.93 150.46 112.22 61.35 89.1221 

### 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 NO x 

### 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 NO x 

### 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 ar ea 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 

### NO x 

### emissions in the nonattainment area ar e projected to dec rease by 89.12 tons. Decreases from U.S. EPA rules covering Tier 2 Motor Vehicle Emissions Standards and Gasoline Sulfur Control Requirements 2 

### , Highway Heavy-Duty Engine Rule 3 

### and Non-road Diesel Engine Rule 4 

### also are factored into the changes. Further , due to implement ation of the NO x 

### SIP Call across the eastern United States, NO x 

### 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 demons trate maintenance of the NAAQS by either showing that future emissions of a pollutant or its precursors will not exceed the level of the attainment invent ory, or by modeling to show that the future mix of sources and emissions ra tes 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 NO x 

### potential to emit is greater than 2500 tons, in accordance with U.S. EPA’s C onsolidated Emissions Reporting Rule (CERR). Ohio EPA prepares a new periodi c 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 es tablished 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 r eductions of VOCs and NO x 

### have contributed to the attainment of t he eight-hour ozone standard. Permittable emission reductions between 2002 and 2004 were due to the application of tighter federal standards on new vehicles. Al so, Title IV of the CAA and the NO x 

### 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-A IR/1997/October/Day-21/a27494.htm
4 http://www.epa.gov/fedrgstr/EPA-AIR /1998/October/Day-23/a24836.htm23 

### 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 NO x 

### 24.63 22.09 2.54 EGU NO x 

### 165.17 101.81 63.36

Requirement 5 of 5 : Provisions for future annual updates of the in ventory to enable tracking of the emission levels including an annual emission st atement from major sources.

Demonstration : As required by Section 175A(b) of the C AA, 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 Technol ogy 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 fo r 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 NO x 

### SIP Call required 22 states to pass rules that would result in significant emission reductions from large EGUs, industrial boilers, and cement kilns in the easte rn United States. Ohio passed this rule in 2001. Beginning in 2004, this rule will account for a reduction of approximately 31 percent of all NO x 

### emissions statewide compar ed 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 implement ation of the NO x 

### SIP Call. Controls for EGUs formally commenced May 31, 2004. Emissions covered by this program have been gener ally 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 NO x 

### reductions that have occurred in Ohio as a result of Title IV of the 1990 CAA Amendments and the beginning of the NO x 

### SIP Call Rule. Ohio developed the NO x 

### Budget Trading Program rules in OAC Chapter 3745-14 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 r eduction of NOx emissions from25 

### EGUs and a 60 percent reduction of NO x 

### 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 pub lished Phase II of the NO x 

### SIP Call that establishes a budget for large (great er than 1 ton per day emissions) stationary internal combustion engines . Ohio EPA’s proposed rule OAC 3745-14-12 addresses stationar y internal combustion engines, all used in natural gas pipeline transmissions. An 82 percent NO x 

### reduction from 1995 levels is anticipated. Completion of the compliance plan is expected by May 1, 2006 and the compliance demonstrat ion will begin May 1, 2007. The 2007 controlled NO x 

### 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, in cluding 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 NO x 

### emission reductions will be approximately 77 percent for passenger cars, 86 percent for smaller SUVs, light trucks, and minivans, and 65 to 95 percent reductions for larger SUVs, vans, and heavier trucks. VOC emissi on 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 di esel 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 NO x 

### from diesel trucks and buses, a large sector of the mobile sources NO x 

### 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 industrie s 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. N on-road diesel equipment, as described in this rule, currently accounts for 47 per cent of diesel particulate matter (PM) and 25 percent of NO x 

### from mobile sources nation wide. 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 impl emented New Source Review (NSR) program. This is addressed in OAC Chapter 3745-31. T he chapter includes provisions for the Prevention of Signi ficant 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 lis ted in the 2002 emission invent ory, or for the closing of which credit was taken in demonstrat ing attainment, will not be allowed to construct, reopen, modify, or recons truct without meeting all applicable permit rule requirement. The review pr ocess will be identical to that used for new sources. Once the area is r edesignated, 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 af orementioned control measures after redesignation. Ohio hereby commits that any changes to its rules or emission limits applicabl e to VOC and/or NO x 

### sources, as required for maintenance of the ozone standard in W heeling, WV-OH: Belmont County, will be submitted to U.S. EPA for approval as a SIP revision.

Ohio, through Ohio EPA’s Legal secti on, has the legal authority and necessary resources to actively enforce any violations of its rules or permit provisions. After redesignation, it int ends to continue enforcing all rules that relate to the emission of ozone precur sors in Wheeling, WV-OH: Belmont County.27 

### LADCO Modeling Analysis for 8-Hour Ozone Standard Assessment

LADCO performed modeling to ev aluate the effect of the NO x 

### 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 conduc ted 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 calc ulated for the Wheeling, WV-OH: Belmont County area, the average decr ease in ozone from the base case modeling run with modeling runs that applied emissi on controls required by the Clean Air Act, NO x 

### SIP Call and Tier II /low-s ulfur 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. NO x 

### emissions will be cut from 4.5 million tons in 2004, to a cap of 1.5 m illion tons by 2009, and 1.3 million tons in 2018 in 28 eastern states and the District of Columbia.

LADCO performed modeling to support t he associated emission reductions for CAIR. This modeling was bas ed on 2001 – 2002 design values for the Wheeling, WV-OH: Belmont County ar ea. Results of the CAIR modeling show Wheeling, WV-OH: Belmont C ounty 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 im plement additional contingency control measures in response to exceeding specified pr edetermined levels (triggers) or in the event that future violations of the ambient standards occur.

Demonstration : Ohio hereby commits to adopt and ex peditiously 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 va lue 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 indi cates 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, t he control measures necessary to reverse the trend taking in to consideration ease and timing for implementation as well as econom ic and social considerations. Implementation of necessary controls in response to a warning level response trigger will take place as expedi tiously 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 Warn ing 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 prom pted whenever a two (2) year average fourth high monitored value of 85 ppb o ccurs 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 addi tional control measures needed to29 

### assure future attainment of NAAQS fo r 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) mont hs from the close of the ozone season that prompted the action level.

Control Measure Sele ction and Implementation Adoption of any additional control meas ures is subject to the necessary administrative and legal process. This process will include publication of notices, an opportunity for public heari ng, 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 t hat measure/control is determined to be sufficient to address the upward trend in air quality, additional local measures may be unnec essary. Furthermore, Ohio will submit to U.S. EPA an analysis to dem onstrate 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 t he ozone NAAQS is meas ured such that nonattainment is indicated at any oz one monitor in the Wheeling-Belmont nonattainment area operated in accor dance with 40 CFR Parts 53 and 58, WVDEP and Ohio EPA will accordingl y select and adopt one or more measures from the list provided below to assure continued attainment. The selection of measures will be bas ed on cost-effectiveness, emission reduction potential, economic and social c onsiderations or ot her factors that WVDEP and Ohio EPA deems appropriate. WVDEP in conjunction with Ohio EPA will solicit input from all inte rested and affected persons in the maintenance area prior to selecting appropriate contingency measures. Because it is not possible at this ti me 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 applicabilit y of 45 CFR 21 (VOC/RACT rule) to include source categories previously ex cluded (e.g. waste water treatment facilities).

2) Revise new source permitting r equirements requiring more stringent emissions control technology and/or emissions offsets.

3) NO x 

### 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 Awarene ss/Ozone Action Days Program, a twopronged program focusing on increasi ng 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 regul atory revisions would be sele cted within three (3) months after verification of a monitored violation wit hin 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 becom e effective within forty-two (42) days after filing and fully implemented within six (6) months after adopt ion. Rule(s) will be filed as a legislative rule(s ) for permanent authorization by the Legislature during the following legislative session. Therefore, less than ei ghteen (18) months should elapse from the time a violation occurs until an appropriate contro l 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 ti me they are under consideration, can be fully evaluated.

Requirement 4 of 4: A list of VOC and NO x 

### sources potentially subject to future controls.

Demonstration : The following is a list of VOC and NO x 

### sources potentially subject to future controls.

NO x 

### RACT

• EGUs

• asphalt batching plants

• industrial/commercial and institutional boilers

• process heaters

• internal combustion engines

• combustion turbines

• other sources greater than 100 tons per year31 

### 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 year32 

## CHAPTER SEVEN

PUBLIC PARTICIPATION

Ohio published a notification for a public hearing and solicitation for public comment concerning the draft redesi gnation 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 32 nd 

### 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: Be lmont County basic nonattainment area has attained the NAAQS standard and complied with the app licable provisions of the 1990 CAA Amendments regarding redesi gnations of basic ozone nonattainment areas. Documentation to that effect is cont ained herein. Ohio EPA has prepared a state implementation and maintenance pl an that meets the requirement of Section 110 (a)(1) of the 1990 CAA.

Ohio has performed an analysis that shows the air quality impr ovements are due to permanent and enforceable measures. In addition, significant regional NO x 

### 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 subj ect to significant tr ansport of pollutants, significant regional NO x 

### reductions will ensure continued compliance (maintenance) with the standards with an increasing margin of safety.

The State of Ohio hereby requests that t he 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 maintenanc e plan provisions contained herein.

### Page left intentionally blank

### 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 approv ed this request on May 16, 2007 (72 FR 27644).

Ohio EPA is now requesting a revision to the maintenanc e 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 an d 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 ch anges were also made to the Appendices of the original submitta l, 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 Co ntrol in collaboration with West Virginia Department of Environmental Protection

June 20, 2006

Revised December 2012This page left in tentionally blanki 

### 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 regulation s .............................................................................................. 24 Implementation of Past SIP Revisions ........................................................................................ 2 4 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 NO x sources...................................................................................................... 30

Chapter Seven Public participation .......................................................................................................... ............ 32

Chapter Eight Conclusions ...................................................................................................................

......... 3233ii 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-O H: 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 Vehi cle 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 NO x Emission Inventory Belmon t Co. Ohio ......................................................... 19 Table 12 NO x Emission Inventory Marshall Co and Ohio Co. WV ..................................... 20 Table 13 CombinedWheeling, WV: NO x Emission Inventory Totals ................................... 20 Table 14 Projected Emission Estimates 2004-201 8 Belmont Co. Ohio ............................. 21 Table 15 Projected Emission Estimates 2004-2018 Marshall Co and Ohio Co. WV .......... 21 Table 16 Combined Projected Emission Estimate s 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 Documentationiii This page left intentionally blank1 

### 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) requir es 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 ai r 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 reclas sified nine of the 1 34 original nonattainment areas to the next lower classification. Sectio n 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 a ttained the eight-hour ozone standard. ii) An approved State Implementation Pl an (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.

BackgroundBelmont County, Ohio, Marshall and Ohio Counties in WV form the Wheeling-Belmont, WVOH interstate nonattainment ar ea 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 Unclassifiabl e/Attainment for the one-hour ozone standard pursuant to the CAA and therefore, has not previously been subject to nonattainment area Formatted: Font color: Black

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Formatted: Font color: Black2 rule-makings. As a result of the 2004 oz one 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 (NO x ) 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 Wheelin g, 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 ea stern Ohio and contains the city of St. Clairsville. Belmont County is bordered by Harrison County to th e 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 gui dance in a document entitled Procedures for Processing Requests to Redesignate Areas to Attainment (redesignation guidance), issued September 4, 1992, to Regional Air Direct ors. This request for redesignation and maintenance plan is based on the redesignation guidance, supplemented with additional guidance received from st aff of U.S. EPA Region V.

Below is a summary of each redesignation crit erion 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 Sy stem (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 state4 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 redesi gnations 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 shall5 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 w ill implement all measures contained in the nonattainment SIP prior to redesignation.

States seeking redesignation of a no nattainment 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 th at 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 (D EP), 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 : Formatted: Font: Not Bold8 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-45 4/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 airquality 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 co nsidered 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 re trieved 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 – 20049 Data source: U.S. EPA Air Quality System (AQS). http://www.epa.gov/ttn/airs/airsaqs/index.htm

1 s t 2 n d 3 r d 4 th 2002-2004 AVERAGE SITE ID COUNTY ADDRESS YEAR %OBS 8-HR 8-HR 8-HR 8-HR 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

1 s t 2 n d 3 r d 4 th 2003-2005 AVERAGE SITE ID COUNTY ADDRESS YEAR %OBS 8-HR 8-HR 8-HR 8-HR 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 4 th 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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Formatted Table10 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 ni trogen oxides from specific source categories (40 CFR Parts 51, 72, 75 and 96, published on October 17, 1998 and referred to as the NO x SIP Call) has significantly reduced emissions from large electric generating units (EGUs), industrial boilers, and cement kilns. Ohio's NO x Budget Trading Program rule was approved on May 25, 2004 [Ohio Administrative Code (O AC) 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 Inters tate Rule (CAIR) is implemented.

Requirement 4 of 4 : A commitment that once redesignated, the st ate 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 contin ue 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. Formatted: Level 1, Justified, Indent: Left: 0", Tab stops: -1", Left + 6.5", Left + Not at 1" + 1.5" + 2" + 2.5" + 3" + 3.5" + 4" + 4.5" + 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 NO x ) representative of the year when the area achieves attainment of the ozone air quality st andard. Ohio also must demonstrate that the improvement in air quality between the year th at 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 NO x SIP Call, many states, includ ing 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 NO x 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 NO x 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 inv entory for Belmont County, including area, mobile, and point sources for precursors of ozone (VOCs and NO x ) for base year 2002. The information belo w 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 inv entories 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 comp iled from Ohio EPA’ s 2002 annual emissions inventory database an d the 2002 U.S. EPA Air Markets acid rain database 1

.

• 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 esti mate the total emissions of pollution caused by vehicles in the area. The travel demand forecasting model is used to predict the total daily vehicle mile s traveled (VMT) and an EPA computer program called MOBILE6.2MOVES2010 is used to calculate emissions permile. 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 Formatted: Underline

Formatted: Normal, Right: 0.5"14 factors”, which are the average emissions per mile (grams/mile) for ozone precursors, NO x and VOC. The MOBILE6.2MOVES2010 model includes a number of variables that affect the em ission factors. These variables have national default values, some of whic h 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 Restrict ed 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 agre ed to by EPA and transportation agencies in a formal interagency consul tation 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 th e total VMT of the analyzed area to getthe 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 vehicl e 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 fa ctor 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 Formatted: Right: 0.5"15 latter more complex method, a table of emission factors.

It should be noted that each year an alyzed 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 NO x 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 NO x 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 clas sified 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 lin k 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. Intraz onal VMT is combined with correspondingemission 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 fo rmats 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 factor s. Likewise, the most current transportation planning data and count data available was used byfrom BelO-Mar and Ohio DOT. Details about each da ta set and how it was used is Formatted: Underline

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Formatted: No widow/orphan control16 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 st reets 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 13.98 6.29 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.

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Formatted: Font: Bold17 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 NO x 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 V OC 2018 Belmont County, OH VOC 1. 3272 Marshall County, WV VOC 0. 3739 Ohio County, WV VOC 0. 8766

T OTAL 2. 5677

NO x Belmont County, OH NO x 1.664.14 Marshall County, WV NO x 0. 3869 Ohio County, WV NO x 1. 0946

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Formatted: Font: Bold18 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 NO x (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 NO x . These correspond to a 1525 percent increase from the 2018 on-road emissions for both VOC and NO x . 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 Memorandu m 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 projec tions are based on the U.S. EPA MOBILE6.2MOVES 2010 model. The analysis is described in more detail in Appendix C. All projecti ons were made in accordance with “Procedures for Preparing Emission s 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 Formatted Table19 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 NO x budgets from the Ohio NO x rule. Emission Inventories for Marshall and Ohio Counties in WV used for this request were developed by DEP staff wi th the support of the contractors for the Visibility Improvement State and Tribal Association of the Southeast (VISTAS), a federally recognized regi onal planning organization. The following tables include sectors Elec trical Generating Unit (EGU-Point), Non-Electrical Generating Unit (Non -EGU), Non-road Mo bile (Non-road), Other Area (Other), Marine, Aircraft, Rail (MAR), On-roa d 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 Othe r 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 * Formatted Table

Formatted: Font color: Auto20 2.604.70 * TOTAL 9.53 10.70 8.68 10.20 7.41 9.51 6. 20 83 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 Y ear 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 Othe r (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 Y ear 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

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Formatted: Font color: Black21 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 NO x 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 NO x Emission Inventory Totals for Base Y ear 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 Formatted: Widow/Orphan control Formatted: Font color: Black

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Formatted: Indent: Left: 0", First line: 0.5"22 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: NO x 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 NO x TOTAL 209.11220.93 139.63150.46

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Formatted: Font color: Black23 Table 14 Belmont County, OH Compar ison of 2004 attainment year and 2018 projected emission estima tes (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 NO x 38.1645.85 23.1326.40 15.0319.46

Table 15 Marshall and Ohio County, WV Combined Comparison of 2004 attainment year and 2018 proj ected 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 V OC 23. 5190 14. 7455 8.779.35 NO x 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 Formatted: Font: Not Bold, Font color: Auto

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Formatted Table24 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.

NO x 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 Requirements 2

, Highway Heavy-Duty Engine Rule 3 and Non-road Diesel Engine Rule 4 also are factored into the changes. Further, due to implementation of the NO x SIP Call across the eastern United States, NO x 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 perm anent and enforceable em ission 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 ra tes 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 NO x 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-A IR/2000/February/Day-10/a19a.htm 3 http://www.epa.gov/fedrgstr/EPA-A IR/1997/October/Day-21/a27494.htm
4 http://www.epa.gov/fedrgstr/EPA-AIR /1998/October/Day-23/a24836.htm25 Demonstration : Permanent and enforceable reductions of VOCs and NO x 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 NO x SIP Call required the reduction of ox ides of nitrogen from utility sources. Table 17 Wheeling, WV-OH: Belmont County Combined Comparison of 2002 base year and 2004 atta inment 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 NO x 12.8124.63 10.9622.09 1.852.54 EGU NO x 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) ye ars 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. Formatted Table26 

### CHAPTER FIVE

CONTROL MEASURES AND REGULATIONS CAA Section107 d)(3)(E)(ii), 10 7(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 Technolo gy 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 NO x SIP Call required 22 states to pass rules that would result in significant emission reductions from large EGUs, industrial boilers, and cement kilns in the eastern United States. Ohio passed this rule in 2001. Beginning in 2004, this rule will account for a reduction of approximately 31 percent of all NO x emissions statewide compared to previous uncontrolled years. The other 21 states also have adopted these rules.

Demonstration : U.S. EPA and Ohio EPA performed modelin g that indicated this area would attain the eight-hour ozone standard with the implementation of the NO x SIP Call. Controls for EGUs formally commenced May 31, 2004. Emissions Formatted: Font: 14 pt, Bold

Formatted: Tab stops: 6", Left + 6.5", Left + Not at 0" + 0.5"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 NO x reductions that have occurred in Ohio as a result of Title IV of the 1990 CAA Amendments and the beginning of the NO x SIP Call Rule. Ohio developed the NO x Budget Trading Program rules in OAC Chapter 3745-14 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 NO x emissions from non-EGUs, compared to historical levels. This c ap will stay in plac e through 2008, at which time the CAIR program will supersede it.

U.S. EPA has recently published Phase II of the NO x SIP Call that establishes a budget for large (great er than 1 ton per day emissions) stationary internal comb ustion 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 NO x reduction from 1995 levels is anticipated. Completion of the compliance plan is expected by May 1, 2006 and the complianc e demonstration will begi n May 1, 2007. The 2007 controlled NO x 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, in cluding sport utility vehicles (SUVs). Under this proposal, automakers will be required to sell cleaner cars, and refineries will be required to make clea ner, lower sulfur gasoline. This rule will apply nationwide. The federal rules will phase in between 2004 and 2009. U.S. EPA has estimated that NO x emission reductions will be approximately 77 percent for passenger cars, 86 percent for smaller SUVs, light trucks, and minivans, and 65 to 95 percent reductions for larger SUVs, vans, and heavier trucks. 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 NO x from diesel trucks and buses, a large sector of the mobile sources NO x inventory.

Clean Air Non-road Diesel Rule In May 2004, U.S. EPA issued the Clean Ai r Non-road Diesel Rule. This rule applies to diesel engines used in industries such as construction, agriculture,28 and mining. It also contains a cleane r fuel standard similar to the highway diesel program. The new standards w ill 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 per cent of diesel particulate matter (PM) and 25 percent of NO x from mobile sources nationwi de. 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 su bstantially 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, 200 1 (66 FR 51570) and received final approval on January 22, 20 03 (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 demonstrat ing 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 rede signated, 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 applicab le to VOC and/or NO x 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 sect ion, has the legal authority and necessary resources to actively enforce any violations of its rules or permit29 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 NO x 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 calc ulated 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, NO x 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. NO x emissions will be cut from 4.5 million tons in 2004, to a ca p of 1.5 million tons by 2009, and 1.3 million tons in 2018 in 28 eastern st ates 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 w ill continue to attain the eighthour ozone NAAQS well into the future. Formatted: No underline, Font color: Auto

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### 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 im plement 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 wa rning level respon se 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 measures31 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 expe ditiously 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 un necessary. Furthermore, Ohio will submit to U.S. EPA an analysis to de monstrate 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 an d adopt one or more measures from the list provided below to assure continued attainment. The selection of measures will be based on cost-e ffectiveness, emission32 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 intere sted 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) NO x 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 an d 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 wi thin 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 select ion. The WVDEP and Ohio EPA will file the draft rule as an emergency rule and will be come 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 NO x sources potentially subject to future controls.

Demonstration : The following is a list of VOC and NO x sources potentially subject to future controls.

NO x RACT

• EGUs

• asphalt batching plants

• industrial/commercial an d 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 (inc luding 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

Formatted: Font: 12 pt, Not Bold, Font color: Black

Formatted: Indent: Left: 0.5", Tab stops: Not at 0" + 0.5" + 6.5"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 32 nd 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 containe d 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 NO x 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 NO x reductions will ensure continued compliance (maintenance) with the standards with an increasing margin of safety. Formatted: Font: 14 pt, Bold36 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 Page left intentionally blank Formatted: Font color: Blue

Formatted: Centered, Indent: Left: 0", Hanging: 0.5", Widow/Orphan control, Tab stops: -1", Left + -0.5", Left + 0", Left + 0.5", Left + 1", Left + 6.5", Right,Leader: ...UNITES STATES ENVIRONMENTAL PROTECTION AGENCY

QUICKLOOK CRITERIA PARAMETERS

Jan. 11, 2007 Report Request ID: 396663 Report Code: AMP450

Selection Criteria Page 1 User ID: GYE

State County City

Site Parameter POC 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 TribalJan. 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 EXCLUDEDJan. 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-HRJan. 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 REPORTJan. 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 OfficeSTREET 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

Introduc tion ................................................................................................ 3

1.0 Point S ources ............................................................................................. 4

2.0 Non Road Sources ..................................................................................... 8

3.0 Area Sour ces ........................................................................................... 12

4.0 MAR Sour ces ........................................................................................... 25

5.0 On Road S ources ..................................................................................... 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, includi ng thirty three counties in Ohio. The 1990 Clean Air Act Amendments (CAAA) requires all st ates to revise and submit state implementation plans (SIPs) for areas wh ich are classified as nonattainment of the National Ambient Air Quality Standar ds (NAAQS) for ozone. The followingsite 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 nonattain ment 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 in ventory. This document presents the 2002 Base Year Ozone State Im plementation Plan (SIP) Emissions Inventory for Ohio as requir ed by the 1990 CAAA. It includes oxides of nitrogen (NO x 

### ) 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 proc edures and the methodologies that were used in the development of summer day vo latile organic co mpound 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 co llection 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 inve ntory 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 in ventory is not being discussed in the document. Ohio EPA did not participate in the generation of the biogenic inventory. The Lake Michigan Air Directors C onsortium (LADCO) utiliz ed U.S. EPA’s Biogenic Emission Inventory System (BEIS) m odel in the Emission Modeling System (EMS) to generate summer weekday emissions for VOC and NO x 

### .

### 4 

## SECTION 1

POINT SOURCES

Emissions and source specif ic 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 de veloped by Ohio EPA, Division of Air Pollution Control (DAPC), to assist t he regulated community in preparing and submitting a variety of electronic permi t applications and reports to DAPC. These data are reported by the Title V faci lities annually as part of the emissions fee/inventory process conducted by Oh io 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 c entral office staff. After review, the data are imported into Ex cel and linked with an Acce ss® database to further process the information into the federally approved National Em ission Inventory (NEI) database format in version 3.0. T he files are quality assured again using U.S.EPA QA/QC software for format and cont ent. The data are finally submitted to LADCO for emissions processing th rough 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 s ource inventory is a hybrid of the federal EGU inventory and the stat e provided non-EGU units.

A major distinction typically made in emi ssions 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 v ent. 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 Identificati on and Data Collection

The sources to be included in the 2002 base year inventory are identified using the Title V STARS database. Facili ty production and emissions data are included in this database. This info rmation 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 acco rdance 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 ((CF 3 ) 2 CFCF 2 OCH 3 )

• Heptafluoropropane ((CF 3 )CFCF 2 OC 2 H 5 )

• Perchloroethylene

• Cyclic, branched or linear completely methylated siloxanes

• Methyl acetate

• Volatile methyl siloxanes

• Acetone



### 1.1.3 Emissions Esti mation Methodologies
Since source reported actual annual emi ssions are used in the 2002 base year inventory, no estimation methods are nec essary. 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 applie d temporal and spatial profiles to the annual emissions to calculat e the July weekday emissions rates. The final point source inventory is split into two separate r eports, 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 f iled from point sources is fugitive emissions. Before 1990, fugiti ve emissions were categorized as area sources due to the lack of detailed informa tion 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 Preparat ion 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 Pl anning & Standards Re search, Triangle Park, NC. May 1991.

Compilation of Air Pollution Emission Fact ors, Fourth Editio n and Supplements, AP-42. U.S. Environmental Protection Agency, Research Triangle Park, NC, September 1985.

### 7 Guidance for the Preparation of Qua lity Assurance Plans for O3/CO SIP Emission Inventories. EPA- 450/4-88-023, U.S. EPA Office of Air Quality Planning and Standards, Research Triangl e Par, NC, December 1988.

Documentation for the 2002 Electric G enerating Unit Nati onal Emissions Inventory (NEI). Eastern research gr oup, Inc., 1600 Perimeter Park Drive, Morrisville, NC 27560 and E.H. Pech an and Associates, Inc., 5528–B Hempstead Way

### 8 

## SECTION 2

NON-ROAD SOURCES

The non-road inventory is generated regio nally 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 Heatheringt on from the Wisconsin Department of Natural Resources that we re distributed to the LADCO States. The first e-mail provides a summary of activities to revi se the NMIM county pr ofile files while the second e-mail provides an overall descrip tion of the modifications related to NMIM.

First e-mail from Grant Heater ington on NMIM Model and Input Descriptions 11/7/05

2.1 Activity Data LADCO states: The activity data have be en 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 f iles: 1700002.act, 1800002.act, 2600002.act, 3900002.act and 5500002.act even though each file is identical. These duplicat es 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 hav e been revised to include Environ’s recreational marine data. The re vised 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 allo cation 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 cons umption (BSFC) emissi on 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 respecti vely. 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 respecti vely. 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_r ev.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 exter nal file structures in NMIM.

2.7 Fuel Data

LADCO states: Pechan revised four t ables (countyyear, countyyearmonth, datasource and gasoline) in the Nationa l 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 revis ed to reference the new activity, allocation, growth, population, and seasonality files describ ed above. NCD tables with names ending in “def” are default versions of the table. See Table 2-1 for the appropriate versions of the tabl es 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 fo r 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 Heather ington on 5/26/2006, provides a synopsis of changes with no referenc es to the file names

Second e-mail mail from Grant Heat herington 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. NM IM consolidates non-road mobile emissions and on-road emissions modeling into a single modeling system. Only the non-road emissions model ing 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 pow ers, activity hours and em ission factors. Before NMIM was run, modificati ons 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 re creational marine equipment using updates provided by ENVIRON International Corporation. Allocation data is used to spatially allocate emissions.

### 11 c. Added emission factors for dies el 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 tempor ally allocate emissions across the months of the year.

e. Revised population data for cons truction and recreational marine equipment using updates provided by E.H. Pechan & Associates, Inc. and ENVIRON International Corporation respectively.

f. Revised growth rates using u pdates 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 equi pment populations to the modeled year.

g. Revised gasoline parameters usi ng updates provided by the state and E.H. Pechan & Associates, Inc. Gasoline parameters include Reid vapor pressure (RVP), oxyg enate content and sulfur content.

h. Replaced the default version of the non-r oad 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 Im provement 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 in ventoried as specific poi nt, mobile, or biogenic sources. For inventory purposes, t hese 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 leve l and therefore, most area source methods are designed to estimate area source emissions at the county level.

Ohio EPA has either used published Em ission Inventory Improvement Program (EIIP) methodologies or selected other methodologies which ar e shared by other states. The decision of which methodolog y to use was largely based on Ohio’s data availability. Data which was not av ailable on a county-level is estimated by assigning a percentage of t he state’s total activity to each county based on the state’s population or empl oyment information.

The area sources discussed in this document are thos e that emit NO X 

### 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 NO X 

### & VOC Emissions NO X 

### Emissions Agricultural Pesticides Residential Coal Combustion Human Cremation Architectural Surface Co atings 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 P esticides (SCC 246850000) VOC
Ohio farmers use mostly Atrizine and 2, 4-D chemicals in pesticide formulations for the three main crops: corn, soy bean 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 i ngredient. The 2, 4-D pesticide contains 46.8 percent active ingredi ent and 53.2 percent inert ingredient. While these percentages are not across t he 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 r eady to use, and spray applied 90 percent of the time.

The emission factor of 700 lb/ton for surfac e 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 emissi ons 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 (typ ically 0.9) (Wiens, 1977)

3.2 Architectural Surface Coatings (SCC 2401001000) VOC
Architectural surface coatings is typi cally considered to be a non-industrial category which homeowners an d 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 Pechan 1 

### 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. population 2 

### 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 coati ng 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 t hat 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 includ ing personal care products, household cleaning products and household pesticides. The majority of VOC emitted into the air from this ca tegory is a result of evaporation of the solvent contained in the product or from t he propellant released during use. This category includes household use as we ll as businesses, institutions, and industrial manufacturing operations.

Industrial solvent applications may also be point source s 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 contri buted VOC emissions from this category.

Ohio used the population 2 

### 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 Manufacturi ng (2415345000) – Vapor/in-line Cleaning for El ectronics & Electrical (2415230000) – Vapor/in-line Cleaning for Other (2415245000)

• Solvent Cleanup – Wipe Cleaning of External Surfaces

Ohio utilizes the methodology requiring employment 3 

### data. Each solvent-cleaning SCC identified above has an EF as indicate d 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 t he Maximum Achievable Control Technology (MACT) rules and are also reduced to account for point source emissions.

Table 3-4 Solvent Cleani ng 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 evaporat ive loss of VOC emissions. This category consists of the VOC losses durin g the transit of gasoline in the trucks. The VOC calculation formula came from EIIP. Because gasoline may go through bulk gasoline plant s 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 ga llon 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 VO C loading losses from underground storage tanks during the transfer of fuel from the trucks. VO C calculations are based on ninety-five (95) percent subm erged 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 ta nks occur during diurnal changes in barometric pressure, temperature and from gasoline evaporation. To calculate VOC emissions from the st orage or breathing losses an EF of 1.000E+00 lb per 1000 gallon gas throughput is used for all c ounties except of t he 16 original nonattainment counties for ozone which em ploy a 1.000E-01 lb/ 1000 gallon of gas throughput. The value for the non-attain ment counties was discussed with Bill Juris, Ohio EPA-DAPC and familiar with Ohio’s gasoline dispensing facilities (GDF) VOC regulations and practices.

Gasoline Distribution Stag e 2 (SCC 2501060100 & 250106103)

Vehicles refueling at service stations ar e the source of VOC emissions as vapors are displaced from autom obile tanks during filli ng (2501060100) and from spillage (2501060103) of gasoli ne. The quantity of displa ced vapors is based on gasoline throughput and is affected by gaso line temperature, gasoline volatility and, most importantly, by the presence of vapor recovery equipment. Stage II vapor recovery equipment is required at al l service stations in the 16 original nonattainment counties for ozone that market in excess of 10,000 gallo ns per month. The VOC emissions factor for filling operat ions 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) perc ent rule effectiveness and a ninety (90) percent rule penetration is used in the ca lculation of emissions. The VOC emissions factor for spillage is 0.7 lbs/1000 gallons of gasoline for t he 72 unregulated counties and 0.4 lbs/1000 gallons of gasoline for the controlled counties.

Since the actual gallons of gasoline so ld 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 consum ption 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 th is category are calculated using Ohio’s population 5 

### 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 us ed in sterilization of hospital surgical equipment and plastic devices that cannot be sterilized by steam. EO is used as a sterilizer because of it s 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 numbe r 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/Pl astics (SCC 2430000000) VOC
This category is calculated using employment 3 

### data for each county for the following North American Industry Cla ssification 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 re commended 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 ot her 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 k ept here for documentation.

3.9 Industrial Surface Coating VOC
This area source contains several categor ies as listed below in Table 3-5. The appropriate NAICS codes are used for each category, shown in Table 3-6, to obtain employment data 3 

### from Bureau of Labor Statis tics 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 emission s 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 onl y 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 c ontrols 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 o perated and the number of

### 19 years it has been closed. A seventy five (75) percent collec tion efficiency and a ninety-five (95) percent c ontrol efficiency are used per AP-42 Compilation of Air Pollutant Emission Factors.

The toxic pollutants are calculated usi ng the methane production rate and the EIIP calculation formula that involves the compound molecular weight and the co-disposal factor. The VOC emissions ar e 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 resi dential 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 population 2 

### 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 tota l flow for this area source category. A twenty (20) percent increased flow is add ed to compensate for Publicly Owned Treatment Works (POTW) fac ilities which are not part of Ohio’s database. The VOC emissions factor is based on the P ennsylvania (PA) factor of the 1996 Protocol.

The 1996 EIIP methodology only offered EF for HAPs. Ohio’s VOC emissions for this category are calculated bas ed on an EF obtained from the PA 1996 Protocol which was the factor being used at the time of th is inventory.

3.13 Traffic Markings (SCC 2401008000) VOC
The number of lane miles per county is obtained from Ohio’s Department of transportation. The nationa l gallon of traffic markings are apportioned to the state using the ratio of state dollar di sbursements in rela tion to the national disbursement. The county level apportionment of paint 2 

### is made using the number of lane miles. The VO C factor (3.36 lb/gal) is ca lculated based on Ohio's assumption of ninety (90) percent wate r based and ten (10) percent oil based paint.

### 20 3.14 Human Cremation (SCC 2810060100) NO X 

### Not all Ohio counties possess a cr ematory so only those counties with crematories are used to calculate the number of cr emations. These numbers are adjusted to account for the cremation of bodies which are brough t in from out of county since the calculations are based on number of deaths per county 2 

### . Ohio has an eighteen (18) percent cremation ra te. Particular matter (PM) emissions are calculated for this category but the methodology did not call for the calculation of NO X 

### emissions so they are not ca lculated. 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 NO X 

### calculations.

3.15 Industrial Fuel Combustion VOC & NO X


### Industrial Distillate Oil Combustion (SCC 2102004000)
Ohio’s fuel consumption is apport ioned per county based on the county’s population 5 

### . The area source VOC and NO X 

### emissions are calculated and adjusted to subtract the emissions due to point sources. A heating value of 140 mmbtu/1000 gallon is used and 4,795,00 0 barrels are consumed in 2002. [MMBTU stand for Million British Thermal Units].

Industrial Residual Oil Combustion (SCC 2102005000)
Ohio’s fuel consumption is apport ioned per county based on the county’s population 5 

### . The area source VOC and NO X 

### 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 (S CC 2102006000)
Ohio’s fuel consumption is apport ioned per county based on the county’s population 5 

### . The area source VOC and NO X 

### emissions are calculated and adjusted to subtract the emi ssions due to point sources.

3.16 Residential Fuel Combustion VOC & NO X


### Residential Coal Combustion (SCC 2104001000)
Ohio’s household consumption of c oal is apportioned per county based on county population 5 

### . NO X 

### and VOC emissions are calcul ated 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 population 5 

### . NO X 

### and VOC emissions are calculated using EF of 18 and

### 21 0.71 lb/1000 gallons distil late fuel respectively. A heating value of 140 mmbtu/1000 gallon is used.

Residential Liquid Petroleu m Gas Combustion (LPG) (SCC 2104007000)
Ohio’s household consumption of LP G is apportioned per county based on county population 5 

### . NO X 

### and VOC emissions are calculated using EF of 13 and 0.49 lb/1000 gallons LPG respectively. T here are 11,432 barrels estimated to be used in 2002.

Residential Natural Gas Combustion (SCC 2104006010)
Ohio’s household consumption of LP G is apportioned per county based on county population 5 

### . NO X 

### 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 NO X 

### emissions from this area source are estimated for seven types of equipment that may be used for residentia l heating involving wood. They are listed below with t he appropriate SCC:

Fireplaces without inserts 2104008001 Fireplaces with inserts cataly tic (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 thos e that burn wood. The following assumptions are applied to those adjusted homes:

92 percent of wood combust ed 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 apporti oned 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 fo r Wood Burners included in Area Sources

SCC 2104008002 210400 8003 2104008004 SCC 2104008010 210400 8050 2104008030 SCC 2104008001 RAPIDS Code Non-Certified N on-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 & NO X


### This area source is considered a combustion source for VOC and NO X 

### emissions which is calculated using EF of 11 and 1.4 lb/ton burned respectively. The residential and commercial structures fi res 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 & NO X 

### emissions into Ohio’s ambient air, other area sources are calculated as well. These additio nal 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 emissi ons factors, they remain incomplete.

Asphalt Paving VOC Forest Fires VOC & NO X 

### Gas & Oil Production VOC Open Burn VOC

3.19 References

1. Documentation For the 2002 Non-Poin t Source National Emission Inventory For CAPS and HAPS. U.S. Environment al 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/dat a/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-Agricult ural. U. S. Environmental Protection Agency. Emissions Inventory Improvement Program. East ern 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 met hod of application.

Daily Vehicle Miles Traveled Reports. Oh io Department of Tr ansportation, 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 A mmonia. 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. Envir onmental 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 Contro l Division. California Ai r Resource Board Inventory method (September 23, 1999). http://www.arb.ca.gov/homepage.htm . (Accessed 2003).

### 24 Spreadsheet formulation provided by “B uzz” 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. C ensus 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 Ad ministration. 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.cremationassociat ion.org/docs/Web01Prelim.pdf (Accessed 2003)

State of California Air Res ources Board Test Report http://www.arb.ca.gov/homepage.htm (Accessed 2003)

Industrial Sector Energy Price and Ex penditure Estimate s, 1970-2001, Ohio. Energy Information Administration. U. S. Department of Energy. http://www.eia.doe.gov/emeu/st ates/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 Fi re 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 comme rcial marines, aircraft and locomotive sources. The marine and locomotive inventory is generated by Environ 1 

### under contract with LADCO and the aircraft in ventory 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 acti vity data sources, engine types and emissions rates. A summary of commerc ial marine activity categories and data sources is shown at Table 4-1.

Table 4-1 Summary of Commercial Mari ne Activity Categories and Data Sources

Commercial Marine Activity Spatial Range Activity Estimation Data Source

Large Deep Draft Near Port Port s and Army Corps of Engineers Large Deep Draft Mid Lake Army Corps of Engineers Barge Traffic Inland Rivers T ennessee 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 C oast 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 Environ 1 

### . The summary of commercial marine emissions estimate fo r Ohio is 248 tons of VOC and 10,307 tons of NO X 

### . This is significantly lower than what is estimated by NEI for 1999 which was 1376 tons of VOC and 44,020 tons of NO X



### .

### 26 4.2 Locomotive Sources
Locomotives are usually the mo st important source of NO X 

### from non-road engines. This category is especially impor tant for Ohio because the State is an important rail center. Rail activity is ty pically broken into five subcategories. These subcategories are listed in Table 4.2.

Table 4.2 Rail Categories

SCC Description Comment 2285002006 Class I operations No rfolk Southern (NS), CSX 2285002007 Class II/III operations R egional 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 expect ed to be the most significant rail operations in most areas, every Class I ra ilroad is asked for information about its rail operation. Norfolk Southern (NS) and CSX provided estimates for their fuel consumption by rail line fo r line-haul estimates but are unable to detail their switching rail activity. They provided activi ty by county in terms of ton-mile of freight movement and estimated fuel cons umption 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 ba sed on national consumption and an employee emissions factor of 10,000 gallons per employ ee. The passenger rail estimate is based on information provid ed 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 Environ 1 

### study and it is referenced at the end of this section.

4.3 Aircraft Vessel Sources

U.S. EPA contracted wit h 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 publish ed (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 In ternational Civil Aviation Organization (ICAO). Finally, the LTO data are comb ined and entered into the FAA Emissions and Dispersion Modeling System (EDMS), wh ich is designed to calculate aircraftspecific emissions.

For all of the above three categories, LA DCO processed the data in EMS 2003 to calculate summer day emissions for VOC and NO X 

### . 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 Co rporation, 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, exc ept jet or turboprop aircraft, are powered by in ternal combustion (IC) piston engines, and nearly all use liquid fuels.

Gaseous fuels, such as compressed nat ural 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 b een used by mobile sour ces in significant amounts since railroads retired their coal- powered steam locomotives in the 1950s.

5.1 Categories of Mobile Sources For inventory and planning pur poses, mobile sources ar e divided into two major categories.

1. On-highway mobile sources, i.e., mo tor 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 sour ces are self-propelled.

Non-road Mobile Sources: Some non-road mobile sour ces (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-se lf-propelled non-road mobile source.

Stationary Sources: Not all movable or portabl e emission sources are mobile sources, however. A small truck-port able cement or hot-mix asphalt plant, for example, may be set up near a constructi on or road-building site. Such plants are classified as stationary s ources, 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 e ngines are mobile sources. Fixed IC engines, such as those that power pipeline compressors or standby generators in electricity plants and elsewhere, are also cl assified as stationary sources.

5.1.1 Categories and Component s 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 evapor ation of fuel from the engine or it’s fuel system

• Refueling emissions

Exhaust Emissions: Are the result of fuel co mbustion and occur only when the engine is running.

Evaporative emissions: Are VOC based only a nd are continuously emitted from an engine’s fuel system , whether the engine is runni ng or not. Gasoline is a very volatile fuel, so total VOC emissi ons from gasoline power ed 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. Evaporat ive emissions for CNG or LPG powered vehicles are negligible because their f uel 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 in clude VOC emissions that occur during refueling.

Refueling Emissions: Are the third category of mobile source emissions. Refueling emissions are entir ely VOC. Although they re sult from the evaporation of fuel, they are distinct from, and not directly rela ted 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 t ank; 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 dr ops of fuel drip or splash on the ground during or after ref ueling 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 Transpor tation (Ohio DOT), LADCO, U.S. EPA, and the Ohio EPA. Estimates of the amounts of NO x 

### 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 D eveloped with MOBILE6.2 Model

MOBILE6.2 Overview:

MOBILE6.2 is a computer program that estimates hydrocarbon (HC), carbon monoxide (CO), NO x 

### , exhaust particulate matter (w hich consists of several components), tire wear particu late matter, brake wear par ticulate matter, sulfur dioxide (SO 2 

### ), ammonia (NH 3 

### ), six hazardous air pollutant (HAP), and carbon dioxide (CO 2 

### ) 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 t hem. The program uses the calculation procedures presented in te chnical reports posted on U.S. EPA's MOBILE6.2 Web page http://www.epa.gov/otaq/models.htm

.

MOBILE6.2 emission factor estimate s depend on various conditions, such as ambient temperatures, travel speeds, op erating modes, fuel volatility, and mileage accrual rates. Many of the vari ables affecting vehicl e emissions can be specified by the user. MOBILE 6.2 will estimate emission factors for any calendar year between 1952 and 2050, inclusive. Vehi cles from the 25 most recent model years are considered to be in ope ration 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 prec ise estimate of local emissions can substitute information that more specifically reflects local conditions. Use of local

### 31 input data will be particularl y common when the local emi ssion 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 par ameters is provi ded 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 va por pressure, sulfur content, oxygenate content, etc.)

• Humidity and solar load

• Registration (age) dist ribution 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 vehicl e 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 specific ations and selections

5.2.4 MOBILE6 References

The following publications provide much of the guidan ce 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 Procedur es 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 ve rsions 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 & Ai r 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 t he 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 Registra tion Distribution by Age

Overview:

The vehicle age distribution determines the fraction of v ehicles operating within each emissions control requirement standard and the deter ioration 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 leve l vehicle registrati on 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 re gistration 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 ca tegory for current and future years. Ohio EPA chose to use local vehicle re gistration data provided by the Ohio Bureau of Motor Vehicles (BMV) to LADCO to develop these inputs.

Method Applicability: This approach is most appl icable in areas where there are significant differences in the local vehi cle fleet age distribution relative to the national average.

Data Sources and Procedures: This approach involves using local vehicle registration data. This is typically availa ble at the county level, but may also be applied using statewide data from the state motor vehi cle 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 r egistration data, which is likely more representative of the local area than the national default.

• Requires minimal additional resour ces, particularly if data is readily available at the county or local leve l from the State d epartment of motor vehicle registration.

• Recommended by U.S. EPA and genera lly is encouraged as a preferred approach over the national default approach.

Details:

Meredith Weatherby of ERG, a subcontract or to LADCO, sent Ohio EPA the files that completed the Ohio registra tion distribution calculations.

These files contained the registration dist ribution fractions for each county code as well as for the entire state. Each c ounty file was in a format that was directly

### 34 useable in the MOBILE 6.2 model runs. Additional fi les contained the fractions as well as the numbers of vehicles for eac h county in a space-delimited file.

5.3.2 Daily Vehicle M iles Traveled (DVMT)

Overview:

Ohio DOT provided the Daily Vehicle Mile s 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 si mple formula multip lies Average Annual Daily Traffic (AADT) by the length of the roadway. For example; if a roadway was 2 miles in length and the AAD T 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 usin g 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 highw ay system, various represent ative counts were used, such as: railroad crossing counts, HPMS sa mple section counts etc. All traffic count data that was not co llected during the current y ear has had a statewide growth factor applied that accounts for systematic growth.

Given the previously ment ioned 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/ava ilpro/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 fact oring process used annu al, estimated, and statewide ADT (average daily traffic) growth factors, derived from the output of a limited number of traffic c ounting stations around the stat e. Although the growth factors are available by functional class, they are more reliable for major roads such as interstates or expressways, wh ich are relatively well-sampled, than for local roads or collectors. The numbers al so do no allow for periodic, large-scale functional reclassification actions wh ich 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 resp onsibility 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 thes e average speed values or how they were estimated. Therefore, st aff believed that it was bes t to use the most recent available data to estimate average speeds. Year 2002 speed data was obtained from Ohio DOT’s Traffic Monitoring Sectio n’s automatic traffi c 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 we re 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 FC 0

6 F C0 8 F C1 1 FC1 4 FC1 7



### Functional ClassSpeed Average Speed

1990 Analysis Speeds 2001 Speed Study

### 36 CAUTION 

## : It should be noted that speeds on fac ilities falling in any one of the federal functional classifications vary gr eatly 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 theseaverage statewide speeds are higher than the average speeds in the nonattainment areas because the non-atta inment counties tend to be more populated and more congested. The document “Highway Vehicle Speed Estimation Procedures for Use in Emissi on Inventories”, September 1991 by Earl Ruiter or Cambridge System atics Inc. is referenced by U.S. EPA’s documented procedures for emission inventory preparat ion. This document suggests post processing travel demand model traffic assignment results to estimate average speeds.

The Ohio DOT Modeling & Forecasting Se ction recommends that Ohio’s travel demand forecasting models and Ohio DO T’s conformity analysis methods be used to establish the roadway mobile s ource portion of Ohio’s SIP budget to assure consistent methods are used for transportation conformity analysis and budgets.

Research:

Time Mean Sped-- Summarizing Automa tic Traffic Recorder (ATR) Speed Data by Functional Class

Year 2002 speed data for July 2002 was prov ided by the Traffic Monitoring (TM) Section as requested by the Mode ling & Forecasting Section (MF).

The TM section generated reports for each ATR in the state of Ohio, grouped the reports by federal functi onal class and provided the su mmary reports to the MF section. The report includes average s peed 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 sp eed 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 sp eeds 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 spee d”. The speeds represent the speed at a poi nt in the middle of a roadway se ction and does not account for slowdowns and del ays 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 es timate 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(FT1 1)+0.09*S(FT21) S(FC12) = 0.91*S(FT1 1)+0.09*S(FT21) S(FC14) = 0.94*S(FT1 2)+0.06*S(FT22) S(FC16) = 0.94*S(FT1 2)+0.06*S(FT22) S(FC17) = 0.94*S(FT1 3)+0.06*S(FT23) S(FC19) = 0.93*S(FT1 6)+0.07*S(FT26)

### 39 Percentage splits for the urban federal functional classes (11trhu 19) were derived by summarizing VMT by Facility Ty pes 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 file s, 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 80.0FC01FC02FC06FC07FC08FC09FC11FC12FC14FC16FC17FC19



### Functional ClassSpeed 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

FC 0

1 FC 0

6 FC 0

8 FC 1

1 FC 1

4 FC 1

7

RAMPS



### Functional ClassSpeed 

### 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 am ong individuals in the Modeling & Forecasting Section that these new space mean speed based average speed estimates were reproducible and defens ible if documented and should therefore be the speeds used with HP MS 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 m ean speed study. (See Table 4)

Reference:

“Draft Technical Memorandum Estimati on 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 (D efault) Data for MOBILE6.2

Per conversation with Mark Janssen at LADCO on 5/14/04, he recommended Ohio use the national defaults for the re st 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 cont racted by LADCO to evaluate the fuel parameters at the co unty level. In a memo to Mike Koerber, at LADCO he states;

“As a part of our project to evaluate the benefits of lowe r 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 bas eline RVP of the fuel in each of the counties, and thus the benefits of any lower RV P 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 reevalua te some of the fuels inputs, so that the baselin e VOC inventories are corre ct, and so that the benefits of RVP control will be accurately estimated.

In particular, ethanol market fractions fo r Michigan, Wisconsin, Indiana, and Ohio should be developed by the stat es or LADCO and utilized. This will also involve a change in the July RVP waiv er 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 fr om 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 re sulted in establishing the following guidelines.

Guidelines:

• No MTBE (ether oxygenated fuel) in Ohio

• 40 percent of Ohio's fuel is eth anol 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 methodol ogy should be forthcoming from LADCO in the near future.

# B ELOMAR REGIONAL COUNCIL Transportation Air Qua lity Analysis and Te chnical Documentation

State Implementation Plan Invento ry 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.....................

.......................................................................................... ........... Pag e 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 1 3 Post Processing ...............

........................ ........................................................................ ............... Page 14

Appendix A – Interagency C onsultation 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 MP O – 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 CompoundsINTRODUCTION

This memorandum documents the air quality analy ses and underlying planning assumptions performed by the Ohio Department of Transportation (ODOT), Di vision 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 Im plementation 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 counti es of Ohio and Marshall in the northern panhandle of West Virginia and Belmont in east-central Ohio. On Ja nuary 5, 2005, the USEPA designated all three counties as non-attainment for the Ozone air quality standard. The d esignation 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, Inte rim Year 2009, and Maintenance Year 2018.Table 1 BELOMAR REGION ON-ROAD MOBILE EMISSION S BY STATE AND COUNTY (2002-04-09-18)LATEST PLANNING ASSUMPTIONS The summer Ozone inventory runs meet the latest pla nning assumption requirement. This report presents the latest population and land use data available that calibra ted the modeling process used to calculate the vehicle emissions for the mobile emissions budgets as well as th e 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 ex ternal roadway “stations” (31) are the basic geographic units for estimating travel patterns. So cioeconomic data used to forecast th ese patterns shown in Table 2 include household population, school enrollment, vehicle registra tions, 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 geoc oded to the zone level. Future year data for each variable were projected th rough various methods. More de tailed explanation of base year and future year data generation for each of the a bove-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, an d properties near the Ohio Valley Mall). Woods and Poole’s employment projections at the county level ar e 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 be fore county level employment is disaggregated. Inassigning 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 re gion, 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 a nd 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 STRUCTURETRAVEL MODELING : A travel demand model (TDM) is the traditional forecasting tool used to examine potential changes in future travel patterns. The road networks within th em include all planned federa l-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 th e 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 lin early 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 b een 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 constr ained 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 Su rvey). The modeling software program utilizes hourly saturation flow rates that are calculated based on road i nventory 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 ti me 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 interna lly 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% diff erent than HPMS estimated VMT. Freeways (federal functional class codes 1, 11, and 12) we re 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 re flected 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 ar ea. 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 Hydr ocarbons, Non-Methane Hydrocarbons, Volatile Organic Compounds, NO x 

### , NO, NO 2

, 

### Total Energy Consumption Strategies None General Output Units = grams, joules and miles Output Emissions Time = hour, Location = cu stom area, on-road emission rates by road type and source use type. Advance Performance None County Data Manager Sources Source Type Population Combinatio n 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 MP O 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 trav el demand model for VHT fractions. Road Type Distribution Use ODOT and WV DOH 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 DefaultTEMPERATURE 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 Clim atic 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 temperat ures 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 th e 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 acc ounted 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 fo r 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 272VEHICLE AGE DISTRIBUTION A grouping of data from Ohio and West Virginia s ources 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 0.006ROAD TYPE DISTRIBUTION The ODOT and WV Division of Highway county summary Vehicle Miles Traveled (VMT) data categorized by federal functional class for the three count y 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 AccessOUTPUT EMISSION FACTORS



### Table 8 shows the first record in a MOVES sample out put (rate per distance) em ission file for year 2005 with I/M programs. For any given month, day of w eek, 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 em issions 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) em ission 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 vehicl e 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 0.01774139P

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_j an_2012APPENDIX A

INTERAGENCY CONSULTATION DOCUMENTATION

### Public Notice Ohio Environmental Protection AgencyRedesignation 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 Environment al Protection Agency (U.S. EPA) revise the current maintenance plan fo r the Ohio portion of the Wheeling Area, (Belmont County), with respect to the 1997 ei ght-hour ozone national ambient air quality standard (NAAQS). Ohio EPA s ubmitted 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 demonstr ated attainment of the NAAQS and there was evi dence 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 budget s 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 r eplaced 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 re lated activities. This notice addresses Ohio EPA’s reliance on the emission projections as evidence of attainment and maintenance and the commitment to instit ute contingency measures if ambient exceedances or violations trigger the contingency plan requi rements. Written co mments 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 c onducted as follows: Tuesday, November 20, 2012 at 3:00P.M., at Bellaire Public Library located at 330 32 nd 

### Street, Bellaire, Ohio.

All interested persons are entitled to att end 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 hear ing 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 redesignat ion. Written statements subm itted after November 20, 2012 may be considered as time and circumst ances 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) 345-8556Hearing 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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affiliated 4: I 0 December 2:20 revise 2: II 16th 4:18
affixed 4:12 defined 4: I 0 K p revision 2:15 1997 2:13
after 3:13 Director 3:4 K 1:10 4:4,15 P2:1 RPR4:15
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ambient 2:14 4:4,15 L party4:9 20th 1:15 3:7,24
and/or 3: I duly4:5 latest2:18 Pataskala 4:12 

## s 2009 2:20

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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-------- B emission 2:16,18 maintenance I :4 plan 1:4 2:11,16 set4:11 26th 4:12
based 2:17 2:20,22 2:11,16 portion 2: 12 Short3:20 28(D)4:10

BASIC 1:4 emissions 2:19 Manager2:4 present 2:24 Simulation 2:20

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

break3:20 3:4,6 1:18 2:3,4 3:21 Professional State 1:12 2:10 303:19 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 

## c 3:9 mobile 2: 16,19 provide 3: 18 Street 1:13 

### ( C2:14:1,1 Expires4:18 MOBILE6.2 public 1:12,13 submitted 3:10 caption 4:7 e-mailed 3:9 2:21 2:4,5,6 4:4 3:13
Center2:5

- model2:19,22 PUBLIC-STA

... certify 4:5 F MODERATOR 4:16 T

circumstances F4:1 1:18 2:3 3:21 purpose2:7 T 4:1,1

3:14 factor 2:22 Motor 2:19 p.m 1:15 3:23 taken 1:10 4:7

Civil4: 10 filed 3:8 MOVES2:21 testimony 3:12

close 3:7 financially 4:9 must 3:6 0 3:18,22 commencing firm 4:10 qualified 4:5 time 3:14,17 4:7

1:14 foregoing 4:6 N quality2:14 today 2:7 3:7,8

comments 2:8 from 2:8,18 N2:1 3:12,13

3:1,2,6,8,10 name2:3 R today's 2:6 G Commission national2: 14 R2:14:1 transcript 4:6

4:18 G2:1 nobody3:17 rates 2:18 true4:6 commissioned generated 2: 18 NONATTAIN

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4:5 given3:12 1:4 receive 3:11 3:23 completed 4:8 go 3:18 Notary 1:12 4:4 received 3:2,6 concerning 3: 1 4:16 record 3:3,5,11 TJ

concluded 3:24 H November 1:14 3:16,18 under4:10 conformity 2:17 hand4:12 3:7,24 4:12 REDESIGNA

... update2:16

consideration hearing 2:6,7

-- . .1:3 U.S2:11,18,21

3:11 3:16,22,24 4:5 0 reduced4:6

considered 3:3 4:7,7 02:1 regarding 2:9 

### v

3:14 hereto 4:9 obtain2:8 Registered 1 : 11 Vehicle2:19

contract4:10 hereunto 4:11 off3:18 4:4

correct4:6 office 4:12 related 4:8 

### w
County 1:5 2:13 I official2:22 3:3 replaced 2:21 way4:8

4:3 included 3:5 3:5,15 Reporter 1:11 Wheeling 2:12

court4:9 Interest 2:5 Ohio 1:1,12,14 4:4 WHEREOF 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