Technical Support Document (TSD) for the

Redesignation Request and Maintenance Plan

for the West Virginia Portion of the Wheeling, WV-OH

1997 PM2.5 Nonattainment Area

Submitted March 2012 by the West Virginia 

Department of Environmental Protection 

TSD Prepared May 2012 by

Jessica L. Fry

Office of Air Monitoring and Analysis, 3AP40

U.S. Environmental Protection Agency, Region 3

1650 Arch Street

Philadelphia, Pennsylvania 19103

/s/

____________________________________________

Reviewed by Walter Wilkie, Associate Director

Office of Air Monitoring and Analysis (3AP40)

May 18, 2012

_________________

Date Signed
I. Introduction

The purpose of this document is to provide a technical summary of the Office if Air Monitoring 

and Analysis (OAMA) review of the emissions inventories submitted with the Redesignation 

Request and Maintenance Plan for the West Virginia Portion of the Wheeling, WV-OH 1997 

PM2.5 Nonattainment Area by the West Virginia Department of the Environment (WVDEP). 

This review does not determine the approvability of the redesignation request or maintenance 

plan. Emissions inventories in a redesignation request are used to show permanent and 

enforceable emission reductions between the year the area was designated as a nonattainment 

area and the year the area came into attainment. In a maintenance plan, the emissions inventories 

are use to reflect the emissions during the time the area came into attainment and are then 

projected to show that the area will remain in attainment. Any questions pertaining to this 

technical summary should be directed to Walter Wilkie, Associate Director, Office of Air 

Monitoring and Analysis, at 215-814-2150 or via email at wilkie.walter@epa.gov. 

II. Emissions Inventories for Redesignation Request (Base Year Inventory)

In a redesignation request, emissions inventories are used to support the States claim that 

the area has permanent and enforceable emissions reductions. In order to do this, the state 

should estimate the percent reduction (from the year that was used to determine the design value 

for designation and classification) achieved from federal and state control measures; this is 

usually termed as the “base year” inventory. The base year inventory contains primary PM2.5

emissions (including condensibles), SO2 and NOx. WVDEP did not include VOC and NH3

emissions having determined them to be insignificant. This section will discuss the 2005 

Nonattainment Year Inventory that was used in the Wheeling Redesignation Request and 

Maintenance Plan submitted by WVDEP.

WVDEP compiled emissions inventories for the West Virginia portion of the Wheeling 

Nonattainment Area. The West Virginia portion of the nonattainment area consists of Marshall 

County and Ohio County. 

The 2005 point source inventory contained emissions for electric generating units 

(EGUs) and Non-EGU sources in Marshall County and Ohio County. EPA guidance for 

emissions inventory development provides that actual emissions should be used for purposes of 

the base year inventory. WVDEP used WV Department of Air Quality’s (DAQ) 2005 annual 

emissions inventory submitted to EPA’s National Emissions Inventory (NEI) database and 

EPA’s Clean Air Markets Division (CAMD) database to compile their inventory. Much of the 

work in developing the inventory involved realigning the EGUs and Non-EGUs from the 2005

dataset submitted to the NEI with the CAMD dataset.

For the 2005 Nonpoint emissions, WVDEP used 2005 NEI v2 data developed by the 

EPA. 
For 2005 Nonroad mobile sources, WVDEP generated the emissions using EPA’s 

NONROAD model. Since marine, air and rail/locomotive (MAR) emissions are not part of the 

NONROAD model, they were calculated separately outside of the NONROAD model. 

The 2005 Onroad Mobile source inventory was developed using the most current version 

of EPA’s highway mobile source emissions model MOVES2010a. The Ohio Department of 

Transportation (ODOT) and the Wood-Washington-Wirt Interstate Planning Commission 

(WWW) performed the analysis in coordination with the Ohio Environmental Protection Agency

and WVDEP, with additional data provided by Ohio EPA, West Virginia Department of 

Transportation (WVDOT), and WVDEP. 

OAMA staff reviewed the files and the emission results provided by WVDEP and found 

them to be acceptable.

III. Emissions Inventories for Maintenance Plan

2008 Attainment Year Inventory and Maintenance Plan Base Year Inventory

The inventory used for the year of attainment is called the Attainment Year Inventory

and also is referred to as the Maintenance Plan Base Year Inventory. This inventory is used as 

the basis for the projected inventories that are used to show the area will remain in attainment. 

The base year inventory contains primary PM2.5 emissions (including condensibles), SO2 and 

NOx . WVDEP did not include VOC and NH3 emissions having determined them to be 

insignificant. This section will discuss the 2008 Attainment Year Inventory that was used in the 

Wheeling Redesignation Request and Maintenance Plan submitted by WVDEP.

The 2008 point source inventory contained emissions for EGUs and Non-EGU sources in 

Marshall County and Ohio County. EPA guidance for emissions inventory development 

provides that actual emissions should be used for purposes of the base year inventory. WVDEP 

used WVDAQ 2008 annual emissions inventory submitted to EPA’s NEI database and EPA’s 

CAMD database to compile their inventory. Much of the work in developing the inventory

involved realigning the EGUs and Non-EGUs from the 2008 dataset submitted to the NEI with 

the CAMD dataset.

For the 2008 Nonpoint emissions, WVDEP used 2008 NEI v1.5 data developed by the 

EPA. Commercial marine vessels and locomotive emissions contained in the 2008 NEI v1.5 

were moved to the nonroad data category. 

For 2008 Nonroad mobile sources, WVDEP generated the emissions using EPA’s 

NONROAD model. Since marine, MAR emissions are not part of the NONROAD model, they

were calculated separately outside of the NONROAD model. 

The 2008 Onroad Mobile source inventory was developed using the most current version 

of EPA’s highway mobile source emissions model MOVES2010a. The ODOT and the WWW

performed the analysis in coordination with the Ohio Environmental Protection Agency and 

WVDEP, with additional data provided by Ohio EPA, WVDOT, and WVDEP. 
OAMA staff reviewed the files and the emission results provided by WVDEP and found 

them to be acceptable.

2015 and 2022 Projection Emission Inventories

Projection inventories are used to show that the area will remain in attainment. WVDEP 

used 2015 and 2022 emission projections for the interim and maintenance plan end year, 

respectively. 

WVDEP used EPA’s Integrated Planning Model (IPM) projections to support the Cross 

State Air Pollution Rule (CSAPR). IPM projections of 2014 (released as 2014, the projected 

future year data provided with this platform is generally representative of several years around 

2012 and 2014 such as 20151), 2020 and 2030 were used. WVDEP compiled Point source EGUs 

from EPA’s CSAPR inventories of 2015 and 2022 was interpolated between 2020 and 2030

inventories. 

For Non-EGU emissions, inventories for 2015 and 2022 were grown from the 2008 

inventory using Workforce West Virginia economic forecasts. 

Nonpoint source emissions for 2015 and 2022 were based on the 2008 inventory using 

Workforce West Virginia economic forecasts. The Workforce WV projections were selected 

because their projections were based more on local data, provided more coverage of various 

categories and a wider range of years, based on 2008. WVDEP compiled and associated 

Workforce WV’s growth factors with North American Industrial Classification System (NAICS) 

codes with WVDEP’s Source Classification Codes (SCCs). Calculations were made and final 

estimates reflected both positive and negative growth.

Nonroad source emissions for 2015 and 2022 were developed using monthly NOROAD 

model runs and summing the monthly data to obtain annual data. MAR emissions for 2015 and 

2022 were based on the 2008 inventory using Workforce WV economic forecasts. The same 

methodology was used to project MAR emissions as was discussed for Nonpoint sources.

Onroad mobile projection emissions for 2015 and 2022 were calculated from 

MOVES2010a produced emission factors as performed by the Ohio Department of 

Transportation.

OAMA staff reviewed the methodologies provided by WVDEP and found them to be 

acceptable.

 

1

Posted June 29, 2011, 2014 Emissions Data Files, 

ftp://ftp.epa.gov/EmisInventory/2005v4_2/2014emis/readme_2005v4_2_CAP_BAFM_HAPs_inventories_2014_inp

uts.txt