Technical Support Document (TSD) for the 

Redesignation Request and Maintenance Plan 

For the West Virginia Portion of the 

Steubenville-Weirton, 0 H-WV 

2006 PM2.5 Nonattainment Area 

Submitted June 2012 by the West Virginia 

Department of Environmental Protection 

TSD Prepared August 2013 by 

Jessica L. Fry 

Office of Air Monitoring and Analysis, 3AP40 

U.S. Environmental Protection Agency, Region 3 

1650 Arch Street 

Philadelphia, Pennsylvania 19103 

Reviewed by Alice H. Chow, Associate Director 

Office of Air Monitoring and Analysis (3AP40) 
I. Introduction 

The purpose of this document is to provide a technical summary of the Office of 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 Steubenville-Weirton, OHWV 2006 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 used 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 Alice H. Chow, Associate Director, 

Office of Air Monitoring and Analysis, at 215-814-2144 or via email at chow.alice@epa.gov. 

II. Emissions Inventories for Redesignation Request 

2005 Nonattainment 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 nonattainment year inventory. The nonattainment year inventory contains 

primary PM2.5 emissions (including condensibles), S02 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 Steubenville-Weirton Redesignation 

Request and Maintenance Plan submitted by WVDEP. 

WVDEP compiled emissions inventories for the West Virginia portion of the 

Steubenville-Weirton Nonattainment Area. The West Virginia portion of the nonattainment area 

consists of Brooke and Hancock Counties. 

The 2005 point source inventory contained emissions for non-electric generating units 

(EGU) sources in Brooke and Hancock Counties. There are no EGU sources in Brooke or 

Hancock County. EPA guidance for emissions inventory development provides that actual 

emissions should be used for purposes of the base year inventory. WVpEP 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 2008 Non-road 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 ofthe NONROAD model. 

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

of EPA's highway mobile source emissions model MOVES2010a. ODOT and the WWWIPC 

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. 

For Non-EGU Point source emissions, inventories for 2015 and 2022 were grown from 

the 2008 inventory using Workforce West Virginia economic forecasts. There are no EGUs 

located in the WV portion of the Steubenville-Weirton, OH-WV area. 

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 emissions data. WVDEP compiled and 

associated Workforce WV's growth factors with North American Industrial Classification · 

System codes with WVDEP's Source Classification Codes. Calculations were made and final 

estimates reflected both positive and negative growth. 

Non-road source emissions for 2015 and 2022 were developed using monthly 

NONROAD model runs and summarizations of monthly data to obtain annual data values. 

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 previously for Nonpoint sources. 

Onroad mobile projection emissions for 2015 and 2022 were calculated from 

MOVES2010a produced emission factors as performed by the ODOT. 

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

acceptable. 
,· 

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 

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

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

ofEPA's highway mobile source emissions model MOVES2010a. The Ohio Department of 

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

(WWWIPC) 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 staffreviewed 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 

Under section 172(c)(3) states are required to submit a comprehensive, accurate, current 

accounting of actual emissions from all sources (point, nonpoint, nonroad, and onroad) in the 

nonattainment area. This inventory contains primary PM2.5 emissions (including condensibles), 

S02, NOx, VOC, and NHJ. In a Maintenance Plan, states are required to submit an inventory used 

for the year of attainment, which is called the attainment year inventory and can also be referred 

to as the maintenance plan base year inventory. This inventory is used as the basis for the 

projected inventories that are used lo show the area will remain in attainment. The base year 

inventory submitted by WVDEP contains primary PM2 5 emissions (including condensibles), 

S02 and NOx . Emissions for VOC and NH3 for the nonattainment area have been supplemented 

with emissions from the 2008 NEI v1.5. This section will discuss the 2008 emissions inventory 

that was used in the Steubenville-Weirton Redesignation Request and Maintenance Plan in order 

to fulfill the 172( c )(3) and attainment year emissions inventory requirements. 

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

and Hancock Counties. There are no EGU sources in Brooke or Hancock 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 vl.S data developed by the 

EPA. Commercial marine vessels and locomotive emissions contained in the 2008 NEI v 1.5 

were moved to the non-road data category.