# Proposed Revision to the

Allegheny County Portion of the Pennsylvania State Implementation Plan

Attainment Demonstration for the Liberty

- Clairton

PM 2.5 

# Nonattainment Area

2006 Standards

Allegheny County Health Department Air Quality Program

May 10

, 201 3Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page

- 2

- {This page left blank for printing purposes}Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page i 

## TABLE OF CONTENTS

1 Executive Summary

................................ ................................ ................................ .............. 1

2 Problem Statement

................................ ................................ ................................ ................ 4

2.1 Introducti on

................................ ................................ ................................ ...................... 4

2.2 Location and Topography

................................ ................................ ................................ 4

2.3 Meteorology

................................ ................................ ................................ ..................... 6

2.4 Monitored Data

................................ ................................ ................................ ................ 8

2.5 Speciation Data Analysis

................................ ................................ ............................... 10

3 Control Strategy

................................ ................................ ................................ .................. 13

3.1 Interstate Transport Rules for EGUs

................................ ................................ .............. 13

3.2 U. S. Steel Mon Valley Works

................................ ................................ ....................... 15

3.3 Source Shutdowns Adjacent to Liberty

- Clairton

................................ ........................... 16

3.4 Regional Inventory Controls

................................ ................................ .......................... 16

4 Emissions Inventory

................................ ................................ ................................ ............ 17

5 Modeling

................................ ................................ ................................ .............................. 19

5.1 Design and Modeling Protocol

................................ ................................ ....................... 19

5.2 Emissions/Modeling Assistance

................................ ................................ ..................... 19

5.3 Methodology

................................ ................................ ................................ .................. 21

5.3.1 Models Selection

................................ ................................ ................................ ..... 21

5.3.2 Loca l Source Treatment

................................ ................................ .......................... 21

5.3.3 Modeling Domains

................................ ................................ ................................ .. 24

5.3.4 Modeled Inventories

................................ ................................ ............................... 26

5.3.5 Projected EGU Inventories

................................ ................................ ..................... 2 8

5.4 Modeled Impacts

................................ ................................ ................................ ............ 33

5.5 Model Performance

................................ ................................ ................................ ........ 38

6 Attainment Tests

................................ ................................ ................................ ................. 40

6.1 Monitored Data Assumptions

................................ ................................ ........................ 40

6. 2 Annual Attainment Test Methodology

................................ ................................ ........... 41

6.3 24

- Hour Attainment Test Methodology

................................ ................................ ......... 43

6.4 Annual Attainment Test Results

................................ ................................ .................... 44

6.5 24

- Hour Attainment Test Results

................................ ................................ ................... 48

6.6 Unmonitored Area Analysis

................................ ................................ ........................... 52

7 Reasonably Available Control Technology and Measures

................................ .............. 53Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page ii

8 Contingency Measures

................................ ................................ ................................ ........ 60

9 Weight of Evidence

................................ ................................ ................................ ............. 62

9.1 Liberty

- Clairton Monitored Data Trends

................................ ................................ ....... 62

9.2 Local Major Source Modifications

................................ ................................ ................ 63

9.3 EGU Deactivations

................................ ................................ ................................ ......... 64

9.4 Population Trends

................................ ................................ ................................ .......... 65

9.5 Wood Stoves and Wood

- Fired Boilers

................................ ................................ ........... 66

9.5.1 Wood Stoves

................................ ................................ ................................ ........... 66

9.5.2 Outdoor Wood

- Fired Boilers

................................ ................................ .................. 66

9.6 Diesel Campaign

................................ ................................ ................................ ............ 67

9.6.1 Idling

................................ ................................ ................................ ....................... 67

9.6.2 City Legislation & Industry Initiatives

................................ ................................ ... 68

9.6.3 ACHD/Heinz Endowment Retrofit Project

................................ ............................ 68

9.6.4 Federally Funded Competitive ARRA Clean Diesel Retrofit Projects

................... 69

9.6.5 State Allocation Diesel Retrofit Project

................................ ................................ .. 69

9.6.6 ACHD Clean Air Fund Retrofits

................................ ................................ ............ 70

9.7 Monitored Data During Low Production Periods

................................ .......................... 71

10 Emergency Episodes

................................ ................................ ................................ ........... 76

11 Legal Documents

................................ ................................ ................................ ................. 77

11.1 Notice of Public Hearing and Comment Period

................................ ......................... 77

11.2 Transmittals of Hearing Notice to PA DEP and EPA

................................ ................ 78

11.3 Proof of Publication and Certification of Public Hearing

................................ .......... 80

11.4 Summary of Public Comments and Responses

................................ .......................... 82

11.5 Certification of Adoption

................................ ................................ .......................... 102

References

................................ ................................ ................................ ................................ .. 103

List of Tables

................................ ................................ ................................ ................................ iii

List of Figures

................................ ................................ ................................ ............................... iv

List of Appendices

................................ ................................ ................................ .......................... v

Acronyms and Abbreviations

................................ ................................ ................................ ..... viLiberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page iii 

### LIST OF TABLES

Table 4

- 1. Baseline 2007 Emissions (Tons/Year)

................................ ................................ .... 18

Table 4

- 2. Future Projected 2014 Emissions (Tons/Year)

................................ ..................... 18

Table 5

- 1. Local Sources for PiG and PSAT Treatment

................................ ........................ 22

Table 5

- 2. 2007 Baseline Case Inventories by Region

................................ ............................ 26

Table 5

- 3. 2014 Future Case Inventories by Region

................................ ............................... 27

Table 5

- 4. SWPA Modeled Emissions Reductions, Point/Area/Nonroad, 2007 to 2014

...... 28

Table 5

- 5. CAIR 2015, CSAPR 2014, and CAMD 2012 SO 2 and NO

x Emissions

............... 29

Table 5

- 6. CAIR 2015, CSAPR 2014, and CAMD 2012 SO 2 and NO

x Emissions adjusted

for PA and Surrounding State Expected Reductions 2013 to mid

- 2015

............. 32

Table 5

- 7. Liberty Quarterly Modeled Averages (μg/m3)

................................ ...................... 34

Table 5

- 8. Liberty Quarterly High Day Modeled Averages (μg/m3)

................................ ..... 35

Table 5

- 9. Clairton Quarterly Modeled Averages (μg/m3)

................................ ..................... 36

Table 5

- 10. Clairton Quarterly High Day Modeled Averages (μg/m3)

................................ . 37

Table 5

- 11. Statistics for the Modeled Daily Liberty Averages Compared to the Liberty

FRM Values, Year

- Round and by Season, 2007

................................ ................... 38

Table 6

- 1. Liberty Annual Attainment Test, by Total Species

................................ .............. 44

Table 6

- 2. Liberty Annual Attainment Test, by Regional/Local Species

.............................. 45

Table 6

- 3. Clairton Annual Attainment Test, by Total Species

................................ ............. 46

Table 6

- 4. Clairton Annual Attainment Test, by Regional/Local Species

............................ 47

Table 6

- 5. Liberty 24

- Hour Attainment Test, by Total Species

................................ ............ 48

Table 6

- 6. Liberty 24

- Hour Attainment Test, by Regional/Local Species

............................ 49

Table 6

- 7. Clairton 24

- Hour Attainment Test, by Total Species

................................ ........... 50

Table 6

- 8. Clairton 24

- Hour Attainment Test, by Regional/Local Species

.......................... 51

Table 7

- 1. RACT/RACM and Alternatives Considered for the Liberty

- Clairton Area

..... 56

Table 8

- 1. Calculation of Required and Excess Emission Reductions

................................ .. 60

Table 8

- 2. Contingency Measures Emission Reductions

................................ ........................ 61

Table 9

- 1. EGU Deactivations in 2012, PA and Surrounding States

................................ .... 64

Table 9

- 2. PM 2.5 FRM Quarterly Averages, 2005

- 2008 and 2009

................................ ......... 74Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page iv 

### LIST OF FIGURES

Figure 2

- 1. Map of the Liberty

- Clairton Area within the Pittsburgh

- Beaver Valley Area

........... 5

Figure 2

- 2 . W ind Frequency and Speed, PM 2.5 Concentration (TEOM Measurements), and

Temperature Roses for the Liberty Monitoring Site, 2007

................................ .......... 8

Figu re 2

- 3. PM 2.5 FRM/FEM Annual Design Values, Allegheny County, 2000

- 2011

................ 9

Figure 2

- 4. PM 2.5 FRM/FEM 24

- Hour Design Values, Allegheny County, 2000

- 2011

.............. 9

Figure 2

- 5. 24

- Hour PM 2.5 Concentrations, 2007 Baseline Year, Liberty and Average of Other

Allegheny County Sites

................................ ................................ ............................. 10

Figure 2

- 6 . Tri

- State Major PM 2.5 Species Concentrations

................................ ........................ 11

Figure 2

- 7 . Localized Excess at Liberty, by Species Composition

................................ ............ 12

Figure 3

- 1. Expected Coal

- Fired P ower Plants Controls for SO 2 and NO

x by 2014

.................. 14

Figure 3

- 2. Tri

- State Expected Coal

- Fired Power Plants Controls for SO 2 and NO

x by 2014

... 14

Figure 5

- 1. Aerial Map of Local Sources for PiG and PSAT Handling

................................ ..... 23

Figure 5

- 2. 36/12/4/0.8 km Modeling Domains

................................ ................................ ......... 24

Figure 5

- 3. 12/4/0.8 km Modeling Domains

................................ ................................ ............... 25

Figure 5

- 4. Initial 4/0.8 km Modeling Domains

................................ ................................ ......... 25

Figure 5

- 5. Reported CAMD SO 2 Emissions (tons), CSAPR States, 2003

- 2012

...................... 30

Figure 5

- 6. Reported CAMD NO

x Emissions (tons), CSAPR States, 2003

- 2012

...................... 30

Figure 5

- 7 . Reported CAMD Heat Inputs (MMBtu), CSAPR States, 2003

- 2012

...................... 31

Figure 5

- 8. Lib erty and Clairton Nearby Receptors

................................ ................................ ... 33

Figure 5

- 9. Liberty Daily Soccer Plot, Baseline 2007

................................ ................................ 39

Figure 9

- 1. Liberty and Clairton FRM Annual Design Values, with Trend Lines Extrapolated to

2014

................................ ................................ ................................ ........................... 62

Figure 9

- 2. Liberty and Clairton FRM 24

- Hour Design Values, with Trend Lines Extrapolated

to 2014

................................ ................................ ................................ ....................... 63

Figure 9

- 3. Population Trends for Allegheny County, 2000

- 2010

................................ ............. 65

Figure 9

- 4. Long

- Term Hourly PM 2.5 TEOM Averages at Liberty and Lawrenceville, 2000

-

2008

................................ ................................ ................................ ........................... 71

Figure 9

- 5. Hourly 2009 PM 2.5 TEOM Averages at Liberty Compared to Long

- Term 2000

- 2008

Averages

................................ ................................ ................................ .................... 72

Figure 9

- 6. Hourly 2009 PM 2.5 TEOM Averages at Lawrenceville Compared to Long

- Term

2000

- 2008 Averages

................................ ................................ ................................ .. 73

Figure 9

- 7. Hourly 2009 PM 2.5 TEOM Average Differences Between Liberty and

Lawrenceville Compared to Long

- Term 2000

- 2008 Data

................................ ........ 75Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page v



### LIST OF APPENDICES

Appendix A : Meteorological Analys e s A

- 1: Investigation of Extended, Consecutive High PM 2.5 Days

A

- 2 : Sullivan, 2007

, Excerpt of Liberty

- Clairton Area Meteorological Evaluation

A

- 3 : Sullivan

, 1996

, Excerpt of Liberty

- Clairton Area Meteorological Evaluation

Appendix B : Monitored Data

Appendix C : Speciation and Source Apportionment Analyses

C

- 1: PM 2.5 Speciation Data Analysis

C

- 2: Positive Matrix Factorization (PMF) Analysis

Appendix D : Liberty

- Clairton Emissions Inventories

D

- 1: Stationary Point Sources

D

- 2: Area Sources

D

- 3: Nonroad Sources

D

- 4: Mobile Sources

Appendix E : Inventory Documentation

E

- 1: MANE

- VU Emissions Inventory TSD 2007 Baseline Case

E

- 2: MANE

- VU Emissions Inventory TSD 2017/2020 Projections

E

- 3: LADCO and SEMAP 2007 Summaries

E

- 4: Nati onal Emissions Inventory (NEI) 2008 V ersion 2 TSD

E

- 5 : Transport Rule (CSAPR) Emissions Inventory TSD

E

- 6: Comparison of EGU Emissions

Appendix F : Inve ntory Revisions

F

- 1: Liberty

- Clairton Emission Inventories and Source Assessment Analysis

F

- 2 : Local Inventory Revisions 2007/2014

F

- 3: Regional 2014 Interpolations/Projections

Appendix G : Modeling Documentation

G

- 1: Model ing Protocol for Liberty

- Clairton Area

G

- 2: Baseline Case 2007 Model Performance

G

- 3: ENVIRON Air Quality Modeling TSD

Appendix H : Attainment Tests

H

- 1: Annual Standard Attainment Test s
H

- 2: 24

- Hour Standard Attainment Test s

Appendix I : RACT /RACM Anal ysisLiberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page vi



### ACRONYMS AND ABBREVIATIONS

ACHD Allegheny County Health Department

AERMOD American Meteorological Society/Environmental Protection Agency

Regulatory Model AQS Air Quality System (EPA)

BACT Best Available Control Technology

CAA Clean Air Act

CAIR Clean Air Interstate Rule

CAMD Clean Air Markets Division

CAMx Comprehensive Air q uality Model with extensions

CFR Code of Federal Regulations

CSAPR Cross

- State Air Pollution Rule

CSN Chemical Speciation Network

CTG Control Technique Guidelines

CTM Chemical (or Chemistry) Transport Model

DON Degree of Neutralization

EC Elemental Carbon

EGU Electric Generating Unit

EPA The United States Environmental Protection Agency

ERC Emission Reduction Credit

FMVCP Federal Motor Vehicle Control Program

FLM Federal Land Managers

FR Federal Register

FRM Federal Reference Method m onitor

FEM Federal Equivalent Method monitor

LADCO Lake Michigan Air Directors Consortium

L

- C Liberty

- Clairton

LPM Local Primary Material

MACT Maximum Achievable Co ntrol Technology

MANE

- VU Mid

- Atlantic/Northeast Visibility Union

MARAMA Mid

- Atlantic Regional Air Management Association

MATS Modeled Attainment Test Software

MFB Mean Fractional Bias

MFE Mean Fractional Error

MOVES Motor Vehicle Emission Simulator m odel

MPO Metropolitan Planning Organization

MSA Metropolitan Statistical Area

MW Megawatt

μ g/m3 Microgram per cubic meter

μm Micrometer, or micron NAAQS National Ambient Air Quality Standard

NAA Nonattainment Area

NEI National Emission Inventory (EPA database)

NH 3 Ammonia

NH 4 Ammonium I onLiberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page vii

NO 3 Nitrate I on NO

x Oxides of Nitrogen

OC Organic Carbon

OCMmb Organic Carbonaceous Mass by Mass Balance

OPP Other Primary PM 2.5 OTC Ozone Transport Commission

PA DEP Pennsylvania Department of Environmental Protection

PBW Particle Bound Water

PennDot Pennsylvania Department of Transportation

PiG Plume

- in

- Grid model

PIT Pittsburgh International Airport

PM Particulate Matter (airborne) of any size

PM 2.5 Particulate Matter less than or equal to a nominal 2.5 microns in aerodynamic

diameter, also referred to as fine particulates

PM 10 Particulate Matter less than or equal to a nominal 10 microns in aerodynamic

diameter

PMF Positive Matrix Factorization model

POA Primary Organic Aerosol

PSAT Particulate Source Apportionment T echnology

RACM Reasonably Available Control Measure

RACT Reasonably Available Control Technology

RFP Reasonable Further Progress

RPO Regional Planning Organization

RRF Relative Response Factor

RVP Reid Vapor Pressu re SANDWICH Sulfate, Adjusted Nitrate, Derived Water, Inferred Carbonaceous Material

Balance Approach

SIP State Implementation Plan

SMAT Speciated Modeled Attainment Test

SMOKE Sparse Matrix Operator Kernel Emissions System

SOA Secondary Organic Aeroso l

SO 2 Sulfur Dioxide

SO 4 Sulf

ate I on SO

x Sulfur Oxides

SPC Southwestern Planning Commission

SWPA Southwestern Pennsylvania

TOA Total Organic Aerosol

TR Transport Rule

TEOM Tapered

- Element Oscillating Microbalance m onitor

TPY Tons Per Year (or Tons/Year) of pollutant emissions

TSD Technical Support Document TS|Pechan TranSystems|E.H. Pechan & Associates

USGS United States Geological Survey

VMT Vehicle Miles Traveled

VOC Volatile Organic Compound

WRF Weather Research and Forecas ting model{This page left blank for printing purposes}Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 1



## 1 Executive Summary

Particulate matter is a mixture of microscopic solids and liquid droplets suspended in air that include: acid salts (such as nitrates and sulfates), organic chemicals, metals, soil or dust particles, and allergens (such as fragments of pollen or mold spores). Fine particle pollution or PM 2.5 describes particulate matter that is less than or equal to 2.5 micrometer (μm, or micron) in diameter, approximately 1/30 th the diameter of a human hair.

Health studies have shown a significant association between exposure to fine particles and

premature death from heart or lung disease. Fine particles can aggravate heart and lung diseases and have been linked to effects such as cardiovascular symptoms, cardiac arrhythmias, heart attacks, respiratory symptoms, asthma attacks, and bronchitis. These effec ts can result in increased hospital admissions, emergency room visits, absences from school or work, and restricted activity days. Individuals that may be particularly sensitive to fine particle exposure include people with heart or lung disease, older adu lts, and children.

In 1997, the United States Environmental Protection Agency (EPA) promulgated PM 2.5 national ambient air quality standards (NAAQS) of 15 .0 μ g/m 3 on an annual basis and 65 μ g/m 3 on a 24

- hour basis. The annual standard is based on a long

- term average of concentrations, while the 24

- hour standard is based on 98 th

- percentile values of maximum daily concentrations. 1

On December 18, 2006, a revised 24

- hour PM 2.5 NAAQS became effective. The United States Environmental Protection Agency (EPA) published air quality designations for the PM 2.5 standard based on air quality monitoring data from 2006

- 2008 in the Federal Register on November 13, 2009

, effective on December 14, 2009. 2 On that date, areas were designated as being either in or out of a ttainment of the revised 24

- hour PM 2.5 NAAQS.

Most of the Pittsburgh Metropolitan Statistical Area (MSA) was designated as an 8

- county
nonattainment area called the Pittsburgh

- Beaver Valley a rea , consisting of Beaver, Butler, Washington, and Westmoreland counties, along with portions of Allegheny, Armstrong, Greene,

and Lawrence counties.

One portion of southeastern Allegheny County, the Liberty

- Clairton area, was designated as a separate nonattainment area within the larger Pittsburgh

- Beaver Valley area. The Liberty

Clairton nonattainment area consists of the boroughs of Glassport, Liberty, Lincoln, Port Vue, and the city of Clairton. Liberty

- Clairton monitored data and other designation factors indicat ed that a more focused strategy for emission contro l was required for this particular area.

By December 14, 2012, three years after the effective date of nonattainment designations, State Implementation Plans (SIPs) for nonattainment areas are due to the U.S. Environmental Protection Agency (EPA). These SIPs must demonstrate that, by December 14, 2014, nonattainment areas under the state/local agency’s jurisdiction will be in attainment of the new

1 NAAQS are given in CFR Title 40 P art 50: http://www.ecfr.gov/cgi

- bin/text

- idx?c=ecfr&tpl=/index.tpl

2 EPA Region III designations: http://www.epa.gov/pmdesignations/2006standards/final/region3.htmLiberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 2

standard. This SIP provides a control stra tegy and attainment demonstration of the 2006 PM 2.5 standards for the Liberty

- Clairton nonattainment area.

Based on 2006

- 2008 monitored data, PM 2.5 design values for t he Liberty

- Clairton area were 18.3

μ g/ m3 on an annual basis and 5 3 on a 24

- hour basis. Modeling for this SIP show s attainment of

the 15.0 μ g/m 3 and 35 μg/m3 s tandard s for future case year 201 4

.

The primary c ontrol measures that enable the Liberty

- Clairton area to demonstrate attainment of

the PM 2.5 NAAQS include:

 Interstate transport rules issued by EPA to reduc e upwind transport of PM 2.5 precursors from power plants

 Upgrades and shutdowns to United States Steel Corporation’s (U. S. Steel) Mon Valley

Works

– Clairton Plant

All other controls included in the attainment demonstration are as developed for Regional Planning Organization (RPO) emission inventories, such as the MANE

- VU (Mid

Atlantic/Northeast Visibility Union) inventory for Mid

- Atlantic and Northeastern states.

A llegheny County Health Department (ACHD) revised the MANE

- VU inventor y in order to more accurately address local emissions impacting the Liberty

- Clairton area.

Other local controls affecting the area that have not been used as part of the modeled

demonstr ation of attainment have been included as “weight of evidence

, ” supporting the case

that the area will achieve emission reductions. These controls include proposed deactivations or upgrades to stationary point sources, area/nonroad source emission rules, and mobile source emission reduction programs.

The modeling demonstration was performed using the Comprehensive Air q uality Model with extensions (CAMx ) model, with the Plume

- in

- Grid (PiG) option for selected local sources. Grid sizes ranged from 36 km for the continental U.S. to 0.8 km for southern Allegheny County and the Liberty

- Clairton area. Years included in the inventory and modeling were 2007 for baseline case and 2014 for future projected case.

Procedures for model ing and attainment tests were followed according to EPA Modeling

Guidance and the ACHD Liberty

- Clairton PM 2.5 M odeling P rotocol. Attainment test methodology was used to combine final modeled results with actual monitored results over the

200 7

- 20 1 4 timefra me. Total mass was reconstructed for PM 2.5 species using the SANDWICH technique ( s ulfate, a djusted n itrate, d erived w ater, i nferred c arbonaceous material balance

approac h ).

Results from the attainment demonstration showed an overall reduction of sulfates , nitrates, and primary PM 2.5 emissions throughout s outh west ern PA, including 2 91 tons of primary PM 2.5 for

the Libert y

- Clairton nonattainment area.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 3

F uture projected design values for the Liberty and Clairton monitor sites are given below :

Projected Annual Design Value Ranges (Standard = 15.0 μg/m3) Liberty 11.6

- 12.1 μg/m3

Clairton 8 .9

- 9.1 μg/m3

Projected 24

- Hour Design Value Ranges (Standard = 35 μg/m3) Liberty 34

- 35 μg/m3

Clairton 18 μg/m3

A Reasonably Available Control Technology (RACT) and Rea sonably Available Control

Measures (RACM) analysis was made for the nonattainment area. No additional controls, or combination of additional controls, would advance the attainment date by one year, so RACT

and RACM are satisfied for this SIP.

This SIP a lso contains a contingency plan that provides assurance that

, should the Liberty

Clairton area fail to attain the NAAQS by the attainment date, the area can be brought back into

attainment as expeditiously as practicable.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 4



## 2 Problem Statement

2.1 Introduction

The Clean Air Act requires a State Implementation Plan (SIP) to be written for any area designated nonattainment for the annual PM 2.5 pollution standard of 15.0 μg/m3 and/or for the daily PM 2.5 pollution standard of 35 μg/m3. In 2009 , the United States Environmental Protection Agency (EPA) designated the Liberty

- Clairton area as a PM 2.5 nonattainment area for the 2006 standards. Liberty

- Clairton is a 12.5 square mile subset of the surrounding Pittsburgh

- Beaver Valley PM 2.5 nonattainm ent area. The area was designated separate ly from the surrounding Pittsburgh

- Beaver Valley area as a result of the complex interaction of a local emission source with meteorology and topography and subsequent air quality ranking factors that are not

consi stent with the surrounding area

. 3



### 2.2 Location and Topography

The Liberty

- Clairton nonattainment area, consisting of Glassport, Liberty, Lincoln, and Port Vue Boroughs and the City of Clairton, is located roughly 10 miles southeast of the C ity of Pittsburgh. The area is made up of complex river valley terrain, approximately 3 miles wide by 5 miles long. It includes a 4

- mile winding portion of the Monongahela River and is bordered by the Youghiogheny River to the east. The area includes rural land, densely populated residential areas, and industrial facilities. The 2010 population of the Liberty

- Clairton area is 18,700 , about

1 .5 % of the population of the Allegheny County

. 4

The river valleys lie at 718 feet in elevation above mean sea level (MSL), while adjacent hilltops can be greater than 1250 feet. Large temperature differences can be observed between the hilltop and valley floor (e.g. 2 °

- 7° F) during clear, light

- wind, nighttime conditions. Strong nighttime drainage flows can cause differences of up to 180° in wind direction with 3

- 4 mph downward flows. Spikes in localized PM 2.5 concentrations have coincided with temperature inversions.

The Liberty

- Clairton area is home to several industrial sources of PM 2.5 pollution. The U. S.

Steel Mon Valley Works

– Clairton Plant is the largest coke plant in the country, producing roughly 4.7 million net tons of coke annually. In addition the Liberty

- Clairton area is also home to Koppers Industries, Inc.’s Clairton Tar Plant, nine permitted minor sources, a nd numerous small sources that do not require operating permits

.

The Liberty

- Clairton and Pittsburgh

- Beaver Valley PM 2.5 nonattainment areas are shown in Figure 2

- 1

.

3 EPA factor analysis for Liberty

- Clairton: http://www.epa.gov/pmdesignations/2006standards/rec/letters/03_PA_EPAMOD3.pdf

4 U.S. Census Bureau data: http://factfinder2.census.gov/faces/nav/jsf/pages/ index.xhtmlLiberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 5

Figure 2

- 1

. Map of the Liberty

- Clairton Area within the Pittsburgh

- Beaver Valley AreaLiberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 6



### 2.3 Meteorology

Temperature inversions contribute to elevated levels of PM 2.5

. ( Note that , for the local region, temperature inversions are measured at least twice daily by balloon

- borne radiosondes sent into the atmosphere by the National Weather Service (NWS) forecasting office near the Pittsburgh International Airport (PIT) and are assumed to represent stability conditions all across the

county. ) A temperature inversion occurs when the air at the surface becomes cooler than the air above it, i.e., the rate of cooling of the air is greatest at ground level whereas the rate of cooling

of the air is less at elevated levels . The cooler , heavier air then becomes trapped at the lower

elevati on . As the major and minor sources of the area continue to emit PM 2.5 pollution and the lower, cooler air becomes buoyantly stable, the PM 2.5 is limited in its upward movement to disperse into the regional flow.

Typically

, upon the inversion’s break, local PM 2.5 is released into the upper atmospheric flow.

Observations have shown that after this break, the Liberty monitor returns to a level comparable

to or less than the concentrations measured at surrounding monitors.

Appendix A contains documentat ion of meteorological conditions affecting Allegheny County in general and the Liberty

- Clairton area in particular. First , a report titled Analysis of Meteorology on Days in 2005

- 2009 when PM 2.5 was A t L east 35.5 

g/m 3 with a Focus on Extended,

Continuous Exceedance Days provides an examin ation of weather conditions observed at the Pittsburgh NWS office on days in 2005 through 2009 when Federal Reference Method ( FRM )

values in Allegheny County reached or exceeded a PM 2.5 level of 35.5 μg/m3 (the level at wh ich an exceedance of the new standard may be registered).

The investigation focused on time periods with extended (i.e., at least four)

, consecutive days

with PM 2.5 of at least 35.5 μg/m3

. During 2005 through 2009, nine such periods were identified.

T h ese extended periods occurred from May through November. The synoptic weather map

features we re rather complicated, but generally indicate d the influence of a high pressure system

in the northeast U.S. with airflow backing from NW to W or SW at the 500 mb level (about 3.4 miles altitude)

. Typically, e vents associated with frontal activity, especially precipitation,

appear ed to dissipate the elevated PM 2.5

.

The maximum temperature for the month wa s usually reached during the extended PM 2.5 periods. In fa ct, seven of the nine extended periods contained the monthly maximum temperature with the remaining two events reporting temperatures just one degree below the monthly high. Temperature departures averaged 7 ° F above normal during the extended periods

and even more within two days after PM 2.5 concentrations dropped below 35.5 μ g/m 3

.

Resultant wind directions were around SW and speeds were light

— typically 3 mph for resultant velocity and 4 mph for mean speed

— during the high PM 2.5 days. Wind directions wer e generally outside the S through W quarter and a bit faster for two days prior to the high days, while the directions tended to be within the S through W quadrant but still faster for two days

after.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 7

Relative humidity averaged at the low 60 percent level . Levels prior to the elevated PM 2.5 event averaged a little higher, while levels after averaged more than ten percentage points higher, which makes sense, since precipitation often occurred to help end the pollution event. Prior to

the event little to n o precipitation was measured; however, the reported substantial amounts associated with the end of the event apparently were sufficient to independently dampen the

PM 2.5 levels or at least to assist with the event’s abridgement.

Finally, atmospheric stabi lity conditions, as indicated by the presence of a significant (i.e., at

least 1 ° C in strength) morning ground temperature inversion, were evaluated. During the

extended PM 2.5 events, morning inversions were generally moderate to strong, averaging 4.7 ° C in strength and topping out at a mean of 200 m. The frequency was relatively high at 83% of mornings. By comparison, such inversions averaged only 2.8 ° C at a height of 150 m and a frequency of 61% before the event and 1.5 ° C at 140 m and 56% after.

Wi th regard to the 2007 base line case year, Figure 2

- 2 displays a wind, pollution , and

temperature rose derived from Liberty continuous monitoring data. As indicated on the graph, the most frequent and fastest winds were generally from the SW through W directions

. Concentrations of PM 2.5 as measured by Tapered

- Element Oscillating M icrobalance (TEOM)

monitor equipment were largest from the S through SW directions. These are directions from which local and long

- range transport carries substantial amounts of fine particulate matter to the Liberty monitoring site from large, stationary sources

. And, l ogically, warmest temperatures were from the southerly directions . T he coolest temperatures were fro m the W through NW

directions.

The second document in Ap pendix A is an excerpt from The Processing of CALMET Files for Allegheny County’s PM 2.5 SIP Analysis (Sullivan, 2007), which was a study conducted for a previous PM 2.5 SIP. This report includes pertinent weather data such as an analysis of the potential f

or low

- level convergence during stable nocturnal conditions in the Liberty

- Clairton

area.

The third item in Appendix A is an excerpt from a report completed earlier for ACHD titled Review of Meteorology at the Clairton Area: Strengthening Dispersion Modeling for State Implementation Plans (Sullivan, 1996). The report’s Executive Summary begins with the following:

“Air quality management in Allegheny County is complicated by valley influences on pollutant transport and dispersion. In particular, val ley meteorology has made it more difficult to establish the connection between emission control strategies and projected air quality benefits. Without sound projections of air quality benefits, costly control decisions can miss the mark, requiring repetit ive attainment demonstrations that are costly to industry and the County. This is an important issue in the County that affects

PM 10 and SO 2 and potentially PM 2.5 (as an issue of the future) in several key valley segments in Allegheny County.”Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 8

Figure 2

- 2

. Wind Frequency and Speed, PM 2.5 Concentration (TEOM Measurements ) , and

T emperature R oses for the Liberty M onitoring S ite, 2007



### 2.4 Monitored Data

PM 2.5 monitors are currently located at 8 different monitoring locations throughout Allegheny County. The Lawrenceville monitor, located roughly 2 miles northeast of downtown Pittsburgh, is generally used to define urban concentrations of PM 2.5 and can sometimes be used to represent regional c oncentrations. Two FRM PM 2.5 monitors are located in the Liberty

- Clairton area. The monitor at Liberty is located atop a school at high elevation near the center of the Liberty

Clairton area. The FRM monitor at Clairton is located atop a school at low e levation in the western portion of the area. Appendix B contain s detailed monitor ed data and EPA Air Quality System (AQS) reports

.

Allegheny County PM 2.5 annual and 24

- hour design values (3

- year averages of annual and 24

- hour 98 th

- percentiles, respective ly) for the timeframe 2000

- 2011 are shown in Figure s 2

- 3 and 2

- 4

. All averages shown are for FRM monitors except Avalon, which was a Federal Equivalent Method (FEM) for 2010 and early 2011. The Liberty monitor shows concentrations that are higher than th e rest of the Allegheny County network

. (Note Figures 2

- 3 and 2

- 4 include some 3

- year periods with low recovery quarters

– i.e., less than 75% valid data per quarter

– as noted in Appendix B.)Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 9

Figure 2

- 3

. PM 2.5 FRM/FEM Annual Design Values, Allegheny County, 2000

- 2011

Figure 2

- 4

. PM 2.5 FRM/FEM 24

- Hour Design Values , Allegheny County, 2000

- 2011Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 10

Figure 2

- 5 shows 24

- hour PM 2.5 concentrations at Liberty compared to the average of other Allegheny County sites on a 1

- in

- 3 sampling schedule for year 2007 ( the baseline case year for the modeling demonstration ) . Although the Liberty monitor shows concentrations similar to

other site s at times , it also shows recurring peak days that are higher than the rest of Allegheny County. These high days lead to an excess of monitored PM 2.5 at Liberty on both long

- term and

short

- term bases.

Figure 2

- 5

. 24

- Hour PM 2.5 Concentrations, 2007 Base line Year, Liberty and Average of Other Allegheny County Sites



### 2.5 Speciation Data Analysis

Speciation data from the Chemical Speciation Network (CSN) and other networks are utilized to

examine PM 2.5 at the component level. The localized excess in the Liberty

- Clairton area has been determined through speciation data analysis

.

A significant portion of the ambient PM 2.5 concentrations in the Pittsburgh Metropolitan Statistical Area (MSA) can be attrib utable to upwind sources in Ohio, West Virginia, and other states. Urban activity additionally contribute s to concentrations within the Pittsburgh MSA,Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 11

compounded by localized activity in the Liberty

- Clairton area. Liberty

- Clairton is therefore impacted by a diverse combination of regional and local PM 2.5 sources

. S ource apportionment results based on speciated data can be found in the report Allegheny County PM 2.5 Source Apportionment Results using the Positive Matrix Factorization Model (PMF Version 3. 0 ) and Conditional Probability Function (CPF) in Appendix C.

A comparison of regional, urban, and local concentrations shows species differences in the Liberty

- Clairton area with respect to the surrounding area

. Quaker City, OH and Dolly Sods,

WV were ex amined as part of the rural/transport portion of PM 2.5 , while Lawrenceville

, Florence, and Greensburg are part of the urban excess portion of PM 2.5

. Figure 2

- 6 shows long

term speciation averages, going west to east through the tri

- state region, by major species over the weighted

- data timeframe for this SIP

.

Figure 2

- 6

. Tri

- State Major PM 2.5 Species Concentrations

Concentrations at m onito r sites roughly show increasing averages from west to east through the Pittsburgh MSA , followed by deceasing averages beyond the MSA . Liberty shows peaks for specific species, indicative of air composition that is not common throughout the greater tri

- state region

. (Note: “Other” component is t he difference between total mass and the sum of the majorLiberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 12

species. “Other” can represent particle

- bound water, trace elements, unmeasured/unknown species, or differences due to analytical testing methods.)

Figure 2

- 7 below shows a pie chart of the long

- term localized species excess at Liberty compared to the urban excess ( i.e., Liberty minus the average of Lawrence ville, Florence, and Greensburg)

. These species are the focus of the modeling effort, since they are leading to the Liberty

- specific con centrations compared to the surrounding area. (Note: EPA’s SANDWICH method modifies the species , including nitrates, organic carbon, and “ other ” component; s ee Section 6, Attainment Tests. )

Figure 2

- 7

. Localized Excess at Liberty

, by Species Composition

An in

- depth analysis of speciated PM 2.5 components in Allegheny County can be found in the

report PM

2.5 Chemical Speciation Analysis for the Liberty

- Clairton Area, 2005

- 2009 in Appendix C

- 1

.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 13



## 3 Control Strategy

This section describes the control strategy implemented in order to reduce levels of PM 2.5 in the Liberty

- Clairton nonattainment area. These controls have been incorporated in the future case modeling for this SIP.



### 3.1 Interstate Transport Rules for EGUs

EPA issued the Clean Air Interstate Rule (CAIR) 5 in March 2005 to reduce the emissions of SO 2 and NO

x from applicable electric generating units (EGUs) located in a participating state (in the

Eastern U.S

. ) that were determined to contribute significantly to ozone and PM2.5 nonattainment areas in a neighboring downwind state (per the CAA §110(a)(2)(D)). CAIR is a regional cap

and

- trade program that established SO 2 and NO

x emission budgets for each particip ating state.

EPA issued the Cross

- State Air Pollution Rule (CSAPR) 6 , originally known as the Transport Rule (TR), in July 2011 as a replacement interstate rule after CAIR was remanded without

vacatur in Dec. 2008. CSAPR was subsequently vacated in Aug. 2012, with CAIR remaining in place for EGU emissions.

While ACHD continues to rely on CAIR as a federal interstate control program for EGUs, the CAIR inventory is an outdated inventory that may not adequately represent future conditions.

T here are inaccu racies in the CAIR projections as developed in 2005 regarding EGU controls and

shut downs. The CSAPR future case 2014 inventory was therefore used in the modeling demonstration as the more recent and realistic dataset for expected EGU emissions. Section 5.3.5 provides more details of CAIR / CSAPR

, recent ly reported , and expected emissions for EGUs

.

The CSAPR 2014 inventory included in the modeling for this SIP was b ased on the inventory developed in July 2011. S upplemental revisions and adjustment s made to CSAPR from Dec. 2011 through June 2012 (not affecting PA allocations) were not included in the modeling inventories.

Figure 3

- 1 shows expected controls for coal

- fired power plants in the E astern U.S. by 2014. 7
Many of the controls involved powe r plants in the tri

- state region of Pennsylvania, Ohio, and West Virginia (see Figure 3

- 2 for focus on this group of power plants , provided by EPA )

. Controls resulting from interstate EGU rules represent the majority of the regional reductions of

PM 2.5 precursors (SO 2 , NO

x ) needed to achieve attainment in the Liberty

- Clairton area.

5 CAIR information is available at: http://www.epa.gov/cair/

. CAIR SO 2 budgets were promulgated upon issuance of the rule (see FR 70 (91) May 12, 2005, Table V

- 1), whereas the CAIR NO

x budgets are promulg ated in 40 CFR 96.140 (annual NO

x ) and 40 CFR 96.340 (ozone season NO

x ). CAIR Phase I

became effective on 1/1/2009 for NO

x and 1/1/2010 for SO 2 . CAIR Phase II, with corresponding reductions in the state budgets, becomes effective on 1/1/2015. For SO 2 , states have no discretion in their allowance allocation approach because CAIR uses the CAA Title IV SO 2 allowances, which have already been allocated in perpetuity to individual units per Title IV of the CAA. In PA, NO

x annual and ozone

season allowances are allocated in accordance with 25 Pa. Code §§145.212 and 145.222, respectively.

6 CSAPR information is available at: http://www.epa.gov/airtransport/

7 Taken from EPA Clean Air Markets: http://epa.gov/airmarkets/quarterlytracking.htmlLiberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 14

Figure 3

- 1

. Expected Coal

- Fired Power Plants Controls for SO 2 and NO

x by 2014

Figure 3

- 2

. Tri

- State Expected Coal

- Fired Power Plants Controls for SO 2 and NO

x by 2014Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 15



### 3.2 U. S. Steel Mon Valley Works

United States Steel Corporation’s (U. S. Steel) Mon Valley Works

– Clairton Plant is the largest

known individual source of PM 2.5 in the Liberty

- Clairton area . The Clairton Plant is located in the City of Clairton on the west bank of the Monongahela River, directly upwind of the Liberty monitor site. Controls at the Clairton Plant represent the majority of the PM 2.5 reductions w ithin the Liberty

- Clairton area for future case year 2014.

A consent order and agreement between ACHD and United States Steel Corporation (U. S. Steel) was signed in March 2008, and amended in September 2010 and July 2011 , requiring a number of actions at the U. S. Steel Mon Valley Works

– Clairton Plant ( and Edgar Thomson Plant ) to resolve specific violations. A ctions to be taken at the Clairton Plant include d a number of
installations and shutdowns, rebuil ding of coke ovens, and other miscellaneous actions. The consent order and agreement is incorporated in the installation permit for the proposed Quench

Towers 5A a nd 7A, constituting a federally enforceable agreement. The consent order as of July

2011 ha s been included in Appendix F

- 2 as supplemental information

. The actions used in the modeling demonstration are as follows:

 Batteries 7, 8, and 9 : Batteries 7

- 9 were permanently shut down on April 16, 2009. The original date for shut down was December 31, 2012 in the consent order and agreement. It is expected that the proposed new C Battery will replace the production of Batteries 7

- 9 at significantly lower emissions.

 Battery 19 : U. S. Steel replace d 25 heating walls on Battery 19 by 2012. If neces sary, an advanced patching plan will be implemented to reduce emissions

.

 Quench Towers 5A and 7A : In September 2010, ACHD and U. S. Steel amended the March 2008 consent order and agreement to include the construction of new low emission quench towers for Batteries 13

- 15 and Batteries 19

- 20 by December 31, 2013. The new Quench Towers 5A and 7A will be used as the primary quench towers for

Batteries 13

- 15 and Batteries 19

- 20, respectively. The current Quench Towers 5 and 7 will serve as auxiliary quench t owers.

Additional Clairton Plant repairs included in the modeling demonstration were due to a previous consent agreement in 2007:

 B Battery : In June 2007, ACHD and U. S. Steel entered into a consent order and agreement to rebuild the B Battery heating w alls, completed in 2010.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 16



### 3.3 Source Shutdowns Adjacent to Liberty

- Clairton

The following facilities immediately adjacent to the Liberty

- Clairton area have been permanently retired, with no request for Emissions Reduction Credits (ERCs). Any future operation at these locations would require a new permit and new source review. T hese sources were therefore removed in the future case 2014 modeling inventory.

 General Motors (GM) Pittsburgh Facility : The GM stamping plant located in West Mifflin, west of Liberty

- Clairton, was retired in April 2011.

 Ryan Metal Company, Inc. : The Ryan Metal scrap processing facility in McKeesport, east of Liberty

- Clairton, was retired in 2009.

 Precoat Metals, a Division of Sequa Corporation : The Precoat metal surface coating facility in McKeesport, east of Liberty

- Clairton, was retired in March 2009.

Tables of emissions by facility for Allegheny and Washington County sources, baseline and future cases, are given in Appendix F

- 2.



### 3.4 Regional Inventory Controls

Future c ase 2014 regional emissions inventories used for this attainment demonstration are as

deve loped for Regional Pla nning O rganization s (RPO s ) such as the Mid

- Atlantic/Northeast Visibility Union (MANE

- VU) and the Lake Michigan Air Directors C o nsortium (LADCO)

. C ontrol factors used to project regional emissions for these inventories incorporate d federal ly

enforceable rules and program s, includ ing the following:

 Federal rules affecting specific sources/categories

 Federal MACT rules

 State

- specific rules

Tables of the inventories used for the modeling demonstration by source category are given in

Section 5. Technical Support Documents (TSDs) for the regional inventories and details of the specific controls a re given in Appendi ces E and F

. Projected emiss ions included the regional

inv entories that are not federally enforceable were used for modeling purposes only.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 17



## 4 Emissions Inventory

Section 51.1008 of 40 CFR Part 51 requires an emissions inventory, based on the requirements of section 172(c)(3) of the CAA, for any PM 2.5 nonattainment area. As specified by the EPA, pollutants inventoried for the Liberty

- Clairton PM 2.5 nonattainment area include PM 10 and PM 2.5 along with precursors SO 2 , NOx, VOC, and NH 3

. Much of the particulate emissions within the nonattainment area are transported from the surrounding area, including S outhwest ern Pennsylvania and states to the west and south of Pennsylvania.

The emissions inventory for Liberty

- Clairton was compiled fo r sources within the nonattainment area (City of Clairton, Glassport Borough, Liberty Borough, Lincoln Borough, Port Vue Borough). Sources in the emissions inventory include stationary point sources, area/nonroad sources, and mobile sources. The stationa ry point sources include two major sources (U. S. Steel Clairton and Koppers), two “synthetic minor” sources (Pennsylvania Electric Coil and Durabond), and seven minor source s.

Emissions inventories for all source classifications were developed for the Mi d

- Atlantic / Northeast Visibility Union (MANE

- VU) for the N ortheastern U.S. for use in regional analyses

and SIPs. The Liberty

- Clairton emissions inventory was developed from t he regional MANE

VU inventories with revisions by TranSystems|E.H. Pechan (TS|P echan) for area, nonroad , and

mobile sources and by ACHD for stationary point sources. (More information on the TS|Pechan contract can be found in Section 5.) Emissions given are “actual” values based on pollutant emission factors and throughputs or capa cities of each emission source . E missions do not represent permitted or “allowable” limits.

The year 2007 was used f or baseline emissions inventory, and year 2014 was used for the projected inventor y

. Local controls were focus ed on direct PM 2.5 emissions from stationary point emissions, while r egional controls for SO 2 and NO

x were based on CSAPR allocations

.

Source categories and methodologies used for the emissions inventory are described below. The inventory listings are included in Appendix D , and information on the development of the baseline and projected emissions and modeling inventories are given in Appendices E and F

.

 Stationary point sources are sources for which ACHD collect s individual emissions

related information. Revisions were made by ACHD to 2007 point source emissions

based on newer emissions estimates that do not reflect originally submitted data. Additionally, the future case includes revisions by TS|Pechan that were not part of the

MANE

- VU projections.

 Area sources are in dustrial, commercial, and residential sources too small or too numerous to be handled individually. These include but are not limited to commercial and residential open burning, architectural and industrial maintenance coatings application and clean

- up, c onsumer product use, and vehicle refueling at service stations.

Area emissions for the Liberty

- Clairton area were estimated by T S |Pechan

.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 18

 Nonroad sources encompass a diverse collection of engines, including but not limited to outdoor power equipment, recreational vehicles, farm and construction machinery, lawn and garden equipment, industrial equipment, recreational marine vessels, commercia l marine vessels, locomotives, ships, and aircraft. N onroad emissions for the Liberty

Clairton area were estimated by T S |Pechan.

 Mobile sources include passenger cars and light

- duty trucks, other trucks, buses and motorcycles. T he Motor Vehicle Emission s Simulator (MOVES) model was utilized to generate emissions based on traffic counts, vehicle speeds, vehicle population growth,

and other factors. Mobile source emissions for the Liberty

- Clairton area were estimated by T S |Pechan

.

Emissions inventory summaries for baseline and future projected cases are shown in Tables 4

- 1

and 4

- 2 below

. These emissions represent sources only within the 5

- mun icipality Liberty

Clairton area and not the surrounding area.

Table 4

- 1

. Baseline 2007 Emissions (Tons/Year)

Liberty

- Clairton Area (2007) PM 2.5 PM 10 SO 2 NO

x VOC NH 3 Stationary Point Sources 946.6 1136.9 1741.3 4841.9 590.5 18.4

Area Sources 26.3 50.5 50.1 38.8 255.9 4.2

Nonroad Sources 15.0 15.9 17.2 437.9 86.6 0.2

Mobile Sources 9.9 10.4 2.1 274.3 172.5 4.7

Totals 997.8 1213.8 1810.9 5592.9 1105.6 27.5

Table 4

- 2

. Future Projected 2014 Emissions (Tons/Year)

Liberty

- Clairton Area (2014) PM 2.5 PM 10 SO 2 NO

x VOC NH 3 Stationary Point Sources 662.7 853.7 1720.5 4349.3 460.1 17.6

Area Sources 25.6 49.5 49.6 38.5 252.0 4.2

Nonroad Sources 12.4 12.7 6.0 387.1 58.5 0.2

Mobile Sources 6.2 6.6 0.9 151.0 95.1 3.4

Totals 706.8 922.4 1777.1 4925.9 865.6 25.3Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 19



## 5 Modeling

5.1 Design and Model ing Protocol

Modeling for the Liberty

- Clairton area was focused on the simulation of regional impacts due to

PM 2.5 precursors and the localized impact s from direct PM 2.5 sources. A photochemical model with plume

- tracking options was utilized at fine grid resolution to adequately model both long

range transport and near

- field impacts.

ACHD followed modeling procedures outlined by the PM 2.5 Modeling Protocol, 2006 PM 2.5 Standards, Liberty

- Clairton Nonattainment Area (given in Appendix G

- 1 ) and by the EPA Modeling Guidance 8 . Modeling was performed using the CAMx model with the Plume

- in

- Grid ( PiG ) and Particle Source Apportionment Technology ( PSAT ) modules for local sourc e tracking.



### 5.2 Emissions /Modeling Assistance

To better understand air

- quality impacts from PM 2.5 emissions in Allegheny County, es pecially in the Liberty

- Clairton area, and to continue with effective programs to attain and maintain the NAAQ S , ACHD contract ed three highly qualified consulting firms. The following three

contractors assisted the ACHD with three different but interrelated PM 2.5 SIP projects.

 TranSystems|E.H. Pechan & Associates (TS|Pechan) of Springfield, VA conducted an in

depth investigati on of transportation and area

- wide sources of PM 2.5 in southern Allegheny County (ACHD contract title Consultant Technical Support for Air Pollutant Area and Mobile Sources Analyses )

 Alpine Geophysics of Arvada, CO operated a state

- of

- the

- science meteorol ogical model (ACHD contract title Meteorological Data Preparation )

 ENVIRON International Corporation (ENVIRON) of Novato, CA provided advanced computer modeling that incorporated the work of the other two contractors into a more

realistic representation o f PM 2.5 impacts in Allegheny County (ACHD contract title Reactive Pollutant Modeling )

Each company had been tasked with a critical component of the “air

- pollution system.” This system consists of sources, dispersion, and receptors of pollutants. Furthermore, air

- pollutant modeling , which was a critical part of the contracting work, ties t he system components together to produce an expected impact of known pollution sources on surrounding communities.

Modeling is a mainstay of today’s environmental field; it is a tool used to simulate real

- world

conditions. For air

- quality studies, “air

- dispersion modeling,” as described by the EPA, “uses mathematical formulations to characterize the atmospheric proces ses that disperse a pollutant

8 Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for Ozone, PM

2.5 , and Regional Haze , U.S. EPA, April 2007.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 20

emitted by a source. Based on emissions and meteorological inputs, a dispersion model can be used to predict concentrations at selected downwind receptor locations.”

Following are brief descriptions of the contract work that helped to produce the demonstration of Allegh eny County’s (including Liberty

- Clairton area) attainment and continued maintenance of

the new 24

- hour PM 2.5 standard.

Consultant Technical Support for Air Pollutant Area and Mobile Sources Analyses contract. A more reliable representation of observed (and forecasted) air

- quality concentrations can be achieved by collecting more and better information. Such collection is part of the ACHD’s continued monitoring efforts throughout the county. However, addition al investigation of PM 2.5 sources had been assigned to contractor TS|Pechan. Specifically, TS|Pechan reviewed existing

PM 2.5 inventories and related documents for local area and mobile sources. The review included field work, records and data searches , a nd calculations necessary to evaluate and modify the existing 2007 SIP emissions inventories. Furthermore, TS|Pechan performed a reasonably available control measures (RACM) analysis, which included examining reasonably available control technology (RACT) , on all area and mobile sources listed in the revised 2007 SIP emissions inventory. This work addressed the “source” component of the air

- pollution system

described above.

Meteorological Data Preparation contract. The “dispersion” aspect of the air

- po llution system was assumed by the ACHD’s analysis of ongoing county and federal meteorological station data along with the addition of Alpine Geophysics work. Under this contract, Alpine Geophysics expedited weather data processing for use with air

- qualit y models such as, but not limited to AERMOD (American Meteorological Society/Environmental Protection Agency Regulatory Model), CALPUFF (originally sponsored by California Air Resources Board), and CAMx (“ C omprehensive A ir quality M odel with e x tensions”). The data processing was performed using the WRF model (a model originally developed with assistance from the National Center for Atmospheric Research, the National Oceanic and Atmospheric Administration, and other government and university organizations). Large

- and fine

- mesh grids at numerous vertical levels were employed to simulate atmospheric conditions across Allegheny County, with a focus on the Liberty

- Clairton area. In addition, the Plume

- in

- Grid (PiG) model was used to simulate fine particulate matter impacts within the Liberty

- Clairton area. (Note that ENVIRON was a subcontractor to Alpine Geophysics on the data preparation work.)

Reactive Pollutant Modeling contract. Finally, to address the “receptors” of the air

- pollution system, ENVIRON w as contracted to assist the ACHD with determining present and future

PM 2.5 concentrations in the county. ENVIRON’s work involved application of CAMx

- a model developed by ENVIRON. Using county tabulated emissions, and mobile and area emission

values ca lculated from the Sparse Matrix Operator Kernel Emissions System (SMOKE) model, along with WRF model results as input to CAMx, ENVIRON conducted air modeling using large and fine grids (see below). Then, after validating the model, ENVIRON ran CAMx for

pr esent conditions and control strategies to demonstrate compliance with the PM 2.5 NAAQS. (Note that Alpine Geophysics was a subcontractor to ENVIRON on the modeling project.)Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 21



### 5.3 Methodology

The modeling methodology focused on the transformation of PM 2.5 p recursors along with the

near

- field impact of primary PM 2.5

. The EPA Modeling Guidance outlines techniques that can be used to model primary PM 2.5 . T his section describes the steps used to model the Liberty

Clairton area. More information on the model method ology can be found in Appendix G ( M odeling D ocumentation).

5.3.1 Model s Selection

The Comprehensive Air Quality Model with extensions ( CAMx Version 5.4, released in October 2011) was used by ENVIRON for the modeling of the Liberty

- Clairton area. The model was designed to include both regional and localized PM 2.5 impacts formed by both primary and secondary mechanisms. CAMx includes several features that were deemed important for PM 2.5 modeling of the Liberty

- Clairton area :

 T wo

- way g rid nesting to allow regional

- and local

- scale imp acts within the same simulation

 S ubgrid

- scale PiG module to sample the puffs for the contributions of local sources

 CB6 chemical mechanism that represents the latest understa nding of photochemistry

 PSAT, important for obtaining the separate contributions from local sources

Since the Liberty

- Clairton excess is composed of both primary and secondary components of

PM 2.5 , emission inputs for CAMx include d all PM 2.5 precursor pollutan ts ( SO 2 , NO

x , VOCs

, NH 3 ) along with primary filterable and condensa ble PM 2.5

.

Meteorological inputs for CAMx were generated by Alpine Geophysics using the WRF model. The WRF grids followed the same grid resolutions as the CAMx, creating several layers of meteorological data for each modeled grid cell.

5.3.2 Local Source Treatment

To account for significant individual emission sources in an area of interest, the Plume

- in

- Gr id (PiG) option incorpor ates a puff/plume model within the large r

- scal e grid model CAMx

. According to Karamchandani, et al., 2011, “[t]he embedded model tracks the sub

- grid scale process (e.g., elevated point source emissions) until the fine scale variability becomes unimportant (referred to as the ‘puff dumping’ or ‘hand

- o ver’ point), at which point the grid model takes over the calculations for that process while the embedded model continues tracking

su b

- grid scale processes.” The authors go on to say that a plume “is represented by a myriad of

three

- dimensional puffs tha t are advected and dispersed according to the local micrometeorological characteristics.... Also, the effects of buoyancy on plume rise and initial dispersion are simulated by solving the conservation equations for mass, heat, and momentum.” Furthermore, “[ c]hemical species concentrations in the puffs are treated as perturbations from the background concentrations

. ”Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 22

Additionally, the Particle Source Apportionment Technology ( PSAT ) option was used to track contributions from a selected group of local sources. This technique enabled the results of both regional and local impacts to be used in the attainment tests (see Section 6).

The local point sources selected for PiG and PSAT handling were based on location within or in

close proximity to the Liberty

- Clair ton area, amount of base line year 2007 pollutant emissions, and source factor “fingerprint” based on the PMF source apportionment. That is, these sources are the sources that are most likely leading to concentrations that are measured at the Liberty

monitor site. Sources selected for local source treatme nt are given in Table 5

- 1 below, along

with their associated precursor and PM 2.5 emission s in tons/year.

Table 5

- 1 . Local Sources for PiG and PSAT Treatment

Facility Precursors ( tpy of SO 2 , NOx,VOC,NH 3 ) PM 2.5

(tpy) Dist. F rom Liberty (km) Comments

AKJ Industries 0.03 0.03 2.0 Liberty

- Clairton area Braddock Recovery 6.62 1. 70 7.7 Located at US Steel ET Plant Clairton Slag 12.87 2.7 5 6.6 Upwind

Consol Coal 0.87 0.66 6.3 Upwind

CP Industries 2.09 0.94 1.7 Proximity to area

Dura

- Bond Industries 14.13 3.60 1.8 Liberty

- Clairton area Eastman Chemical Resins 25.50 17.5 7 7.0 Upwind, major source

ELG Metals 0.48 1.93 1.5 Liberty

- Clairton area

Gardner Denver Nash 4.09 0.1 9 5.1 Upwind GM Metal Stamping 9.24 1.28 3.6 Proximity to area

Guardian Industries 782.94 19.97 8.5 Upwind, major source Kelly Run Sanitation 19.15 4.98 8.5 Upwind

Kinder

- Morgan 4.64 0.20 3.5 Proximity to area Koppers Tar Plant 29.13 5.96 2.3 Liberty

- Clairton area Liberty Pultrusions 11.74 0.05 3.1 Proximity to area

Marathon Ashland 6.94 0.37 8.4 Upwind

Mid

- Continent C & C 6.55 1.79 2.8 Liberty

- Clairton area Mon Valley Transport 0.00 3.7 6 1.7 Liberty

- Clairton area

Penn sylvania Elec tric Coil 2.38 0.0 3 2.3 Liberty

- Clairton area

Precoat Metals 27.78 0.7 6 2.3 Proximity to area Ryan Metals 0.42 7.10 2.3 Proximity to area Sanyo 8.60 1.7 3 7.0 Upwind, located at Eastman Tube City IMS Braddock 0.00 3.07 7.7 Located at US Steel ET Plant Tube City IMS Clairton 0.00 0.31 2.8 Liberty

- Clairton area

TYK Refractories 12.60 0.48 5.9 Upwind

US Steel

– Clairton Plant 7136.30 929.18 2.1 Liberty

- Clairton area

US S teel

– E T Plant 2255.84 803.29 7.8 Major source

US Steel

– Irvin Plant 1223.10 51.12 2.9 Major source Allegheny Energy Mitchell 2145.24 79.85 14.3 EGU GenOn Energy Elrama 10324.22 512.82 8.9 EGULiberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 23

The local sources are additionally shown on an aerial map in Figure 5

- 1 below.

Figure 5

- 1

. Aerial Map of Local Sources for PiG and PSAT HandlingLiberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 24

5.3.3 Modeling Domains

WRF and CAMx were run for a 36/12/4/0.8 km domain structure, defined as follows:

 36 km continental U.S. (CONUS) domain to be the standard RPO domain, run as a stand

alone simulation, results post

- processed to define Boundary Conditions (BCs) for the 12 km North East U.S. ( NEUS) doma in

 12 km NEUS domain that includes states in the Midwestern and Northeastern U.S. that the Cross State Air Pollution Rule (CSAPR) identified as contributing significantly to

PM 2.5 at Liberty

 A 4 km domain that covers southwestern Pennsylvania (SWPA) and adjacent areas in West Virginia and Ohio

 A nested grid of 0.8 km (800 m) for the area within and surrounding the Liberty

- Clairton

area

Figures 5

- 2 through 5

- 4 show maps of the modeled domains.

Figure 5

- 2

. 36/12/4/0.8 km Modeling DomainsLiberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 25

Figure 5

- 3

. 12/4/0.8 km Modeling Domains

Figure 5

- 4

. Initial 4/0.8 km Modeling Domains (Note: The final 0.8 km domain was reduced in size.)Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 26

5.3.4 Modeled Inventories

E missions inventories for the baseline year modeling were based on MANE

- VU/ MARAMA 9

LADCO 10 , and the Southeastern Modeling, Analysis, and Planning (SEMAP 11 ) Project 2007

inventories. In cases where the 2007 data was unavailable, U.S. EPA’s 2008 National Emissions Inventory (NEI 12 ) was back

- casted to 2007. Revisions were made by ACHD and TS|Pechan to Allegheny County sources, based on updated stack test data, corrections t o emissions or stack parameters, or revised emission calculation methodologies. Details of the inventory development are given in Appendi ces E and F

. Table 5

- 2 below shows the 2007 modeled inventories by U.S. region

.

Table 5

- 2

. 2007 Baseline Case Inventories by Region

Source Category Liberty

Clairton

Area Allegheny

County/SWPA MA NE

- VU

States SEMAP/

SESARM

States LADCO

States Other

States

Area TS|Pechan

2007 MANE

- VU

2007v3 Final (corrected) MANE

- VU

2007v3 Final EPA 2008

NEIv1.5 EPA 2008

NEIv1.5 EPA 2008

NEIv1.5

NonRoad TS|Pechan

2007 MANE

- VU

2007v3 Final (corrected) MANE

- VU

2007v3 Final SEMAP 2007

Draft EPA 2008

NEIv1.5 EPA 2008

NEIv1.5

OnRoad

Mobile LADCO

2007BaseCv8 LADCO

2007BaseCv8 LADCO

2007BaseCv8 LADCO

2007BaseCv8 LADCO

2007BaseCv

8 LADCO

2007BaseCv

8

NonEGU

Point ACHD 2007

(corrected) ACHD 2007

(corrected)/

MANE

- VU

2007v3 Final MANE

- VU

2007v3 Final SEMAP 2007

Draft EPA 2008

NEIv1.5 EPA 2008

NEIv1.5

EGU

Point --- MANE

- VU

2007v3 Final MANE

- VU

2007v3 Final SEMAP 2007

Draft 2007 day

specific hourly CEM 2007 day

specific hourly CEM

Fires 2007

BlueSky Fire

Emissions
EPA, 2010 2007 BlueSky

Fire Emissions
EPA, 2010 2007

BlueSky Fire

Emissions
EPA, 2010 SEMAP 2007

Draft 2007

BlueSky Fire

Emissions
EPA, 2010 2007

BlueSky Fire

Emissions
EPA, 2010

Biogenics Day Specific

SMOKE

BEIS Day Specific

SMOKE

- BEIS Day Specific

SMOKE

BEIS Day Specific

SMOKE

- BEIS Day Specific

SMOKE

BEIS Day Specific

SMOKE

BEIS

9 http://www.marama.org/

10 http://www.ladco.org/

11 http://www.metro4

- sesarm.org/SEMAPAbout.asp

12 http://www.epa.gov/ttn/chief/net/2008inventory.htmlLiberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 27

Emissions inventories for the future year modeling were based on MANE

- VU inventories interpolated to 2014, LADCO 2014 projections applied to NEI 2008 data, and CSAPR 2014

inventories. 13 Similar to the baseline case, r evisions were made by ACHD and TS |Pechan to Alleg heny County sources for 2014. Table 5

- 3 below shows the 2014 modeled inventories by U.S. region.

Table 5

- 3 . 2014 Future Case Inventories by Region

Source Category Liberty

Clairton

Area Allegheny

County/SWPA MANE

- VU

States SEMAP/

SESARM

States LADCO

States Other

States

Area TS|Pechan

2014 MANE

- VU

2017v3 Final (corrected, interpolated to 2014) MANE

- VU

2017v3 Final (interpolated to 2014) CSAPR 2014

cs_05b CSAPR

2014 cs_05b CSAPR

2014 cs_05b

NonRoad TS|Pechan

2014 MANE

- VU

2017v3 Final (corrected, interpolated to 2014) MANE

- VU

2017v3 Final (interpolated to 2014) CSAPR 2014

cs_05b CSAPR

2014 cs_05b CSAPR

2014 cs_05b

OnRoad

Mobile CSAPR

2014
cs_05b CSAPR 2014

cs_05b CSAPR 2014

cs_05b CSAPR 2014

cs_05b CSAPR

2014 cs_05b CSAPR

2014 cs_05b

NonEGU

Point ACHD

2014 (corrected) ACHD 2014

(corrected)/

MANE

- VU

2017v3 Final (interpolated to 2014) MANE

- VU

2017v3 Final (interpolated to 2014) CSAPR 2014

cs_05b EPA 2008

NEIv1.5,

w/LADCO

2014 factors CSAPR

2014 cs_05b

EGU

Point --- CSAPR 2014 TR1_remedy CSAPR 2014

TR1_remedy CSAPR 2014

TR1_remedy CSAPR

2014 TR1_remedy CSAPR

2014 TR1_remedy

Fires 2007

BlueSky

Fire

Emissions
EPA, 2010 2007 BlueSky

Fire Emissions
EPA, 2010 2007 BlueSky

Fire Emissions
EPA, 2010 SEMAP

2007 Draft 2007

BlueSky

Fire

Emissions
EPA, 2010 2007

BlueSky

Fire

Emissions
EPA, 2010

Biogenics Day

Specific

SMOKE

BEIS Day Specific

SMOKE

- BEIS Day Specific

SMOKE

- BEIS Day Specific

SMOKE

BEIS Day Specific

SMOKE

BEIS Day Specific

SMOKE

BEIS

13 http://www.epa.gov/ttn/chief/emch/index.html#finalLiberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 28

Baseline

- to

- future case m odeled emission s reductions f or point, area, and nonroad source categories (including Marcellus Shale area source emission estimates for Fayette, Greene, Washington, and Westmoreland counties, see Appendix F

- 2 for details) in Southwestern PA (SWPA) are shown below in Table 5

- 4. Reductions are shown by county or source group

–

c ounties do not include electric generating units ( EGUs ) , which are listed as a separate source group for SWPA. Note: Allegheny County excludes Liberty

- Clairton area emissions.

Table 5

- 4

. SWPA Modeled Emissions Reductions, Point/Area/Nonroad, 2007 to 2014

County/ Group SO2 NOx VOC NH3 PM10 PM2

. 5 Allegheny

- 551

- 2612

- 2319 3

- 250

- 309 Liberty

- Clairton A rea

- 33

- 544

- 163

- 1

- 287

- 287 Armstrong

- 44

- 110

- 295 3

- 14

- 20

Beaver

- 134

- 837

- 451 36

- 63

- 57

Butler

- 169

- 658

- 400 8

- 37

- 45 Fayette

- 104 985 1146 3

- 46

- 6

Greene

- 28 3013 4610 3

- 16 58

Indiana

- 75

- 182

- 264 5

- 9

- 22

Lawrence

- 68

- 1735

- 268 7

- 47

- 37 Washington

- 166 3479 7420 8

- 19 65

Westmoreland

- 446 822 784 5

- 82

- 41

EGUs

- 499871

- 46592 580 380

- 200 1972

EGUs showed the largest reductions for SO 2 and NO

x , while Allegheny County and the Liberty

Clairton area showed the largest reductions for PM 2.5 . Increases in NO

x and VOC emissions for Fayette, Greene, Washington , and Westmoreland Counties are due to projected increases in shale

gas exploration and production.

5.3.5 Projected EGU In ventories

As mentioned in Section 3.1, CSAPR was used for the modeling of projected EGU emissions for

2014. The CAIR inventory was developed in 2005 on a 2001

- based air quality modeling platform, while CSAPR was developed in 2011 using a 2005

- based platf orm. The CSAPR future case inventory was used in the modeling as the more recent and realistic dataset for expected EGU emissions.

The CAIR and CSAPR future case remedy inventories (2015 and 2014, respectively) focused on

the control of PM 2.5 precursor e missions of SO 2 and NO

x for the Eastern U.S. but also included emissions for the rest of the country. For a look at the validity of the CAIR and CSAPRLiberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 29

i nventories in relation to recent reported data, future case emissions for CAIR 14 and CSAPR 15

were compare d to 2012 reported values from EPA’s Clean Air Markets D ivision ( CAMD)

. 16

Emissions shown in Table 5

- 5 below represent totals from CAIR and CSAPR future cases along

with CAMD 2012 reported emissions for the following source categories: cogeneration, electric utility, and small power producer. Projected and reported SO 2 and NO

x emissions totals are shown by region: contiguous U.S. (excluding AK, H I, and DC), CSAPR

- controlled states (28 eastern states), and PA and surrounding states (PA, OH , WV, and MD ).

Table 5

- 5 . CAIR 2015 , CSAPR 2014 , and C AMD 2012 SO 2 and NO

x Emissions

Region SO 2 CAIR 2015 (tons) SO 2 CSAPR 2014

(tons) SO 2 C AMD 2012

(tons)

Contiguous U.S. 5,223,044 3,356,577 3,316,811

CSAPR

- Controlled

States 4,618,909 2,919,042 3,036,681

PA and Surrounding

States 531,325 419,233 687,176

Region NO

x CAIR 2015 (tons) NO

x CSAPR 2014

(tons) NO

x C AMD 2012

(tons)

Contiguous U.S. 2,199,729 1,890,578 1,706,442

CSAPR

- Controlled

States 1,561,493 1,428,480 1,354,453

PA and Surrounding

States 222,766 279,901 278,436

CAMD data shows that r eported emissions of SO 2 and NO

x have decreased significantly in the U.S. in recent years. Reported 2012 emissions for the contiguous U.S. and CSAPR states are already well below CAIR 2015 levels and are near or below CSAPR 2014 emissions. Only PA and surrounding states are significant ly higher than projected CAIR or CSAPR values.

Long

- term (10

- year) trends for reported C AMD emissions and heat inputs were examined for the

E astern U.S. to determine if emissions are steadily decreasing without a loss in electricity

demand. F igures 5

- 5 t hrough 5

- 7 show trends for SO 2 , NO

x , and heat inputs for CSAPR

controlled states over the timeframe 2003

- 2012

.

14 2015 Final CAIR Modeling: http://www.epa.gov/airmarkets/progsregs/epa

- ipm/cair/index.html

15 2014 CSAPR TR1 Remedy: ftp://ftp.epa.gov/EmisInventory/2005v4_2/2 014emis

16 CAMD database: http://ampd.epa.gov/ampd/ (accessed 2/13/2013)Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 30

Figure 5

- 5

. Reported CAMD SO 2 Emissions (tons), CSAPR States, 2003

- 2012

Figure 5

- 6

. Reported CAMD NO

x Emissions (tons), CSAPR States, 2003

- 2012Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 31

Figure 5

- 7 . Reported CAMD Heat Inputs (MMBtu), CSAPR States, 2003

- 2012

The trend s in Figu res 5

- 5 through 5

- 7 indicate that SO 2 and NO

x are steadily decreasing in the

Eastern U.S. over the 10

- year timeframe with little change in heat input levels; therefore, decreases are not due solely to low electricity generation . It may be reasonable to as sume that

the emission reductions will continue to occur in the 2013

- 2014 timeframe.

Furthermore, deactivations of many EGUs occurred in 201 2 or have been proposed for 2013 through mid

- 2015 due to compliance with the Me rcury Air Toxics Standards and/ or ot her factors. To examine the potential reductions due to the announced deactivations for PA and surrounding states, C AMD 2012 emission levels were revised to reflect the deactivat ions for

201 2 through mid

- 2015, as tracked by PJM Interconnection

. 17 ( Deactivations occurring in 2012

were included to remove partial

- year 2012 CAMD emissions ).

Also, SO 2 emissions from the Homer City plant in Indiana County, PA were revised to reflect the planned installation of control equipment by Oct. 2014. 18

17 PJM Interconnection: http://www.pjm.com/~/media/planning/gen

- retire/pending

- deactivation

requests.ashx (pending as of Mar. 11, 2013)

18 Homer City Plan Approval: http://files.dep.state.pa.us/RegionalResources/SWRO/SWROPortalFiles/AQ_HomerCity/Issued%20Plan %20Approval%20PA

- 32

- 00055H%204

- 2

- 12.pdfLiberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 32

T able 5

- 6 show s projected and reported SO 2 and NO

x emissions totals for U.S. regions, similar to

the T able 5

- 5 , but with C AMD 2012 emissions revised to include expected reductions due to proposed deactivations and planned controls

.

Table 5

- 6 . CAIR 2015 , CSAPR 2014 , and C AMD 2012 SO 2 and NO

x Emissions adjusted

for PA and Surrounding State Expected Reductions 2013 to mid

- 2015

Region SO 2 CAIR 2015 (tons) SO 2 CSAPR

2014 (tons) SO 2 CA M D 2012

with PA/Surrounding Expected Reductions by

mid

- 2015 (tons)

Contiguous U.S. 5,223,044 3,356,577 2,901,220

CSAPR

- Controlled

States 4,618,909 2,919,042 2,621,090

PA and Surrounding

States 531,325 419,233 322,020

Region NO

x CAIR 2015 (tons) NO

x CSAPR

2014 (tons) NO

x C AM D 2012

with PA/Surrounding Expected Reductions by

mid

- 2015 (tons)

Contiguous U.S. 2,199,729 1,890,578 1,656,886

CSAPR

- Controlled

States 1,561,493 1,428,480 1,304,897

PA and Surrounding

States 222,766 279,901 241,772

The revised CAMD emissions with known expected reductions for PA and surrounding states

would lower the current reported levels of SO 2 and NO

x to below CSAPR levels for all regions

. Note that CAIR NO

x is lower than both CSAPR and reported levels for PA and surrounding

states, suggesting that the CAIR NO

x projections may have been inaccurate

.

Additionally , many EGUs that were projected to install emission controls are switching to natural gas. These fuel switches have not been accounted for in the CSAPR inventory as developed in 2011

, resulting in a potentially conservative modeling approach for the future case.

Considering the comparisons to both CAIR and reported data, the CSAPR 2014 remedy case is an adequate inventory of expected EGU emissions for modeling purposes. Emissions totals are given by state (and by facili ty for PA and surrounding state CAMD data ) in Appendix E

- 6.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 33



### 5.4 Modeled Impacts

CAMx modeled impacts for the 0.8 km grid in and around the Liberty

- Clairton area were combined on an hourly basis with local ly

- tracked 100 m “nearby” receptor concentrations at the Liberty and Clairton sites. These 100 m receptors were defined as receptors surrounding the

FRM site at similar elevation that would measure similar concentrations to the actual monitor

FRM location

.

Figure 5

- 8 shows the “nearby” receptors that were used for Liberty (40 receptors) and Clairton (51 receptors).

Figure 5

- 8

. Liberty and Clairton Nearby Receptors

Additional details on the nearby recep tors are given in the Modeling Protocol in Appendix G

- 1.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 34

Modeled CAMx quarterly average and high day (top 10%) average impacts for the Liberty receptors, by regional and local impacts, are given in Tables 5

- 7 and 5

- 8

. The local and regional impacts were tracked separately by the CAMx model using the Particulate Source Apportionment Technology tool. The modeled impacts from point sources identified for local treatment are summed as the local portion of the CAMx impacts.

All values in Tables 5

- 7 and 5

- 8 are in μg/m3, with the species defined as follows:

SO4 = sulfate ion POA = primary organic aerosol

NO3 = nitrate ion SOA = secondary organic aerosol

NH4 = ammonium ion EC = elemental carbon OTHER = unspeciated PM 2.5

Table 5

- 7

. Liberty Quarterly Modeled Averages (μg/m3)

Local Impacts

2007 SO4 NO3 NH4 POA SOA EC OTHER TOTAL

1Q 0.310 0.016 0.090 0.169 0.000 0.202 1.557 2.344

2Q 0.407 0.008 0.118 0.221 0.000 0.274 2.018 3.046

3Q 0.612 0.002 0.184 0.282 0.000 0.373 3.134 4.587

4Q 0.439 0.013 0.154 0.203 0.000 0.280 2.386 3.475

2014 SO4 NO3 NH4 POA SOA EC OTHER TOTAL

1Q 0.254 0.020 0.079 0.159 0.000 0.190 1.215 1.917

2Q 0.347 0.014 0.091 0.209 0.000 0.264 1.632 2.557

3Q 0.491 0.004 0.141 0.261 0.000 0.358 2.464 3.719

4Q 0.352 0.019 0.124 0.186 0.000 0.264 1.845 2.790

Regional Impacts

2007 SO4 NO3 NH4 POA SOA EC OTHER TOTAL

1Q 2.475 2.040 1.348 3.478 0.053 1.386 4.190 14.970

2Q 4.791 0.402 1.244 1.008 0.022 0.823 1.714 10.004

3Q 7.259 0.051 1.369 0.997 0.029 1.026 2.293 13.024

4Q 3.542 1.632 1.421 3.664 0.039 1.531 4.560 16.389

2014 SO4 NO3 NH4 POA SOA EC OTHER TOTAL

1Q 1.668 1.818 1.062 2.773 0.044 0.606 3.677 11.648

2Q 2.251 0.378 0.880 0.707 0.017 0.318 1.454 6.005

3Q 3.047 0.065 0.986 0.659 0.023 0.405 1.966 7.151

4Q 2.057 1.242 1.008 2.968 0.034 0.665 3.921 11.895Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 35

Table 5

- 8

. Liberty Quarterly High Day Modeled Averages (μg/m3)

Local Impacts

2007 SO4 NO3 NH4 POA SOA EC OTHER TOTAL

1Q 0.788 0.058 0.211 0.424 0.000 0.507 3.748 5.736

2Q 1.036 0.024 0.383 0.383 0.000 0.589 5.679 8.094

3Q 1.145 0.001 0.429 0.366 0.000 0.587 6.005 8.533

4Q 0.880 0.076 0.206 0.395 0.000 0.433 4.222 6.212

2014 SO4 NO3 NH4 POA SOA EC OTHER TOTAL

1Q 0.615 0.082 0.189 0.387 0.000 0.464 2.664 4.401

2Q 0.835 0.054 0.301 0.357 0.000 0.577 4.456 6.580

3Q 1.001 0.009 0.378 0.384 0.000 0.671 5.597 8.040

4Q 0.690 0.093 0.165 0.358 0.000 0.391 3.043 4.740

Regional Impacts

2007 SO4 NO3 NH4 POA SOA EC OTHER TOTAL

1Q 5.520 3.924 2.649 7.158 0.097 2.892 8.052 30.292

2Q 11.162 0.114 1.987 1.140 0.026 1.218 2.425 18.072

3Q 15.827 0.030 2.199 1.223 0.038 1.406 3.334 24.057

4Q 6.915 5.755 3.513 11.620 0.089 3.995 11.931 43.818

2014 SO4 NO3 NH4 POA SOA EC OTHER TOTAL

1Q 3.873 3.752 2.242 5.642 0.080 1.185 6.959 23.733

2Q 4.071 0.541 1.406 0.896 0.024 0.531 2.085 9.554

3Q 4.675 0.072 1.503 0.878 0.031 0.681 2.993 10.833

4Q 4.062 4.377 2.498 9.488 0.084 1.678 10.372 32.559Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 36

Modeled CAMx quarterly average and high day (top 10%) average impacts for the Clairton receptors, by regional and local impacts, are given in Tables 5

- 9 and 5

- 10

. Like with the Liberty impacts, the local and regional impacts were tracked separately by the CAMx model using the Particulate Source Apportionment Technology tool. The modeled impacts from point sources

identified for local treatment are summed as the l ocal portion of the CAMx impacts.

All values in Tables 5

- 9 and 5

- 10 are in μg/m3, with the species defined as follows:

SO4 = sulfate ion POA = primary organic aerosol

NO3 = nitrate ion SOA = secondary organic aerosol

NH4 = ammonium ion EC = elemental carbon OTHER = unspeciated PM 2.5

Table 5

- 9

. Clairton Quarterly Modeled Averages (μg/m3)

Local Impacts

2007 SO4 NO3 NH4 POA SOA EC OTHER TOTAL

1Q 0.338 0.021 0.096 0.171 0.000 0.247 1.952 2.825

2Q 0.560 0.008 0.148 0.274 0.000 0.403 3.141 4.534

3Q 0.732 0.002 0.203 0.319 0.000 0.534 4.029 5.819

4Q 0.333 0.014 0.128 0.175 0.000 0.291 1.819 2.760

2014 SO4 NO3 NH4 POA SOA EC OTHER TOTAL

1Q 0.245 0.023 0.084 0.153 0.000 0.233 1.365 2.103

2Q 0.421 0.015 0.117 0.247 0.000 0.382 2.254 3.436

3Q 0.512 0.004 0.153 0.281 0.000 0.507 2.799 4.256

4Q 0.247 0.017 0.108 0.160 0.000 0.281 1.325 2.138

Regional Impacts

2007 SO4 NO3 NH4 POA SOA EC OTHER TOTAL

1Q 2.498 2.034 1.342 2.875 0.051 1.404 3.766 13.970

2Q 4.880 0.419 1.256 1.007 0.022 1.006 1.759 10.349

3Q 7.306 0.047 1.371 1.018 0.029 1.224 2.365 13.360

4Q 3.559 1.616 1.389 3.088 0.037 1.665 4.155 15.509

2014 SO4 NO3 NH4 POA SOA EC OTHER TOTAL

1Q 1.685 1.821 1.055 2.206 0.043 0.603 3.295 10.708

2Q 2.294 0.385 0.882 0.688 0.017 0.432 1.486 6.184

3Q 3.066 0.062 0.986 0.660 0.023 0.530 2.016 7.343

4Q 2.066 1.222 0.973 2.403 0.033 0.721 3.542 10.960Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 37

Table 5

- 10 . Clairton Quarterly High Day Modeled Averages (μg/m3)

Local Impacts

2007 SO4 NO3 NH4 POA SOA EC OTHER TOTAL

1Q 1.590 0.114 0.438 0.752 0.000 1.028 9.296 13.218

2Q 1.443 0.016 0.336 0.671 0.000 0.851 8.368 11.685

3Q 1.578 0.005 0.515 0.605 0.000 1.080 9.552 13.335

4Q 1.007 0.071 0.527 0.538 0.000 0.998 5.510 8.651

2014 SO4 NO3 NH4 POA SOA EC OTHER TOTAL

1Q 1.071 0.134 0.374 0.615 0.000 0.837 5.741 8.772

2Q 1.244 0.031 0.342 0.744 0.000 0.973 7.188 10.522

3Q 1.345 0.007 0.477 0.734 0.000 1.343 8.194 12.100

4Q 0.692 0.092 0.419 0.454 0.000 0.836 3.491 5.984

Regional Impacts

2007 SO4 NO3 NH4 POA SOA EC OTHER TOTAL

1Q 5.017 2.865 2.365 6.313 0.080 3.189 6.856 26.685

2Q 6.637 0.172 1.264 1.499 0.027 1.522 2.218 13.339

3Q 12.759 0.113 1.963 1.292 0.035 1.599 2.909 20.670

4Q 6.385 5.583 3.271 10.178 0.086 4.374 10.816 40.693

2014 SO4 NO3 NH4 POA SOA EC OTHER TOTAL

1Q 3.635 3.211 2.071 5.048 0.071 1.351 6.352 21.739

2Q 1.946 0.428 0.875 0.991 0.023 0.611 1.783 6.657

3Q 3.678 0.117 1.080 0.693 0.026 0.583 1.945 8.122

4Q 3.752 4.429 2.266 8.394 0.083 1.915 9.615 30.454

Model input/output and post

- processing files can be obtained by request.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 38



### 5.5 Model Performance

Model performance review provides a method to examine modeled data in comparison to actual

monitored data for the same timeframe. For the baseline 2007 case, model performance for Liberty was examined by ACHD and ENVIRON

.

The EPA Modeling Guidance recommends performance statistics for use in operational evaluation of the modeled results. Equations for the Mean Fractional Bias (MFB) and Mean Fractional Error (MFE) metrics are given below:

Mean Fractional Bias (%)

Mean Fractional Error (%)

These equations were used to test the accuracy of the modeled results com pared to the monitored

data . “Goal” represents a good statistical relationship, while “criteria” represents average results (limits were used in regional model evaluations, given in the EPA Modeling Guidance)

. Statistics shown below in Table 5

- 11 were generated for total daily PM 2.5 (all species).

Table 5

- 11

. Statistics for the Modeled Daily Liberty Averages Compared to the Liberty

FRM Values, Year

- Round and by Season, 2007

Daily Results Mean Fractional

Bias (MFB) Mean Fractional

Error (MFE)

1 st Quarter 26.65% 42.53%

2 nd Quarter

- 24.21% 34.71%

3 rd Quarter

- 28.94% 38.93%

4 th Quarter 16.95% 40.05%

Year

- Round

- 2.62% 39.03%

GOAL Within ± 30% ≤ 50%

CRITERIA Within ± 60% ≤ 75%Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 39

Positive MFB bias (MFE is always positive) indicates that the model overestimated in 1 st and 4 th

quarters , with the 2 nd and 3 rd quarters showing negative bias (underestimation)

. All quarter s and

year

- round statistics fell within the goal range, indicative of good results

.

Figure 5

- 9 shows a “soccer plot” that visually display s the daily statistics as data points within the goal and criteria ranges (red and blue boxes, respectively). All points lie within the “goal” of

the soccer plot.

Figure 5

- 9

. Liberty Daily Soccer Plot , Baseline 2007

A detailed report of model performance , including performance by individual species, is given in Appendix G

- 2

.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 40



## 6 Attainment Tests

This section describes the calculations used for the attainment tests for Liberty and Clairton. Since the CAMx modeling provided modeled data on both total and regional/local bases, both options were tested for future attainment. Weighted values for 2005

- 2009 were used for this

demonstration.



### 6.1 Monitored Data Assumptions

Speciation and PMF analys e s (Appendix C) show that a diverse mix of PM 2.5 components makes

up the localized excess in the Liberty

- Clairton area. The majority of the excess was measured a s carbons, but other components such as ammonium sulfate and crustal component were also part

of the excess

.

The SANDWICH ( s ulfate, a djusted n itrate, d erived w ater, i nferred c arbonaceous material balance approac h ) method outlined by EPA Modeling Guidance reconstructs PM 2.5 species to better represent FRM monitored data. The SANDWICH species reconstructions are shown in detail in Appendix H (Attainment Tests). Using this technique, species are adjusted as follows:

 Nitrate is based on retained estimations

 Indirect ammonium is dependent on sulfate, nitrate, and degree of neutralization (DON)

values

 Organic carbon is calculated by mass balance from all other species

 Water is calculated from sulfate, nitrate, and ammonium values

Assumptions are made with the monitored data handling to ensure that all species are accounted for and that the speciation data are correctly used for each FRM site. Assumptions for the CSN speciation and FRM data for Liberty and Clairton are listed below:

 Organic carbon mass by mass balance accounts for all differences between the FRM and other species and can include trace elements or other species that may be associated with organic carbon.

 Indirect ammonium best accounts for the ammonium and the calculated particle

- bound

wate r species. Any measured excess of ammonium may or may not be retained on the FRM filter and is accounted for in the organic carbon mass by mass balance. Furthermore, the ammonium generated by the CAMx model is based on associated

sulfate and nitrate.

 “O ther” component represents unknown m ass from the speciation monitor. The SANDWICH technique recalculates most of the “other” component as particle

- bound water associated with hygroscopic compounds.

 Liberty speciation data is assumed to be representative of both the Liberty and Clairton monitored areas. I.e., the Liberty species compositions are representative of Clairton butLiberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 41

at smaller overall concentrations. Liberty species compositions are therefore used with Clairton weighted FRM values in the design value calculation.

 No exceptional events or anomalies are evident in the FRM or speciation data. However, species mass balance problems led to the exclusion of two quarters of Liberty speciation

data in the attainment test calculations.

 Degrees of Neut ralization (DON) of sulfate are held constant for baseline to future case. DON has been supplied with the pre

- calculated EPA speciation SMAT/MATS data set.



### 6.2 Annual Attainment Test Methodology

Speciated Modeled Attainment Test (SMAT) methodology for the a nnual standard is given in the EPA Modeling Guidance. 19 Species reconstruction is based on the SANDWICH technique. The steps for the annual SMAT are listed below:

 Calculate 5

- year weighted FRM quarterly averages . This is the average of the 200 5

- 200 7

, 200 6

- 200 8 , and 200 7

- 200 9 3

- year quarterly averages. This is done for the Liberty

and Clairton FRM monitored values.

 Calculate retained nitrate (NO3

r ) by speciation sample . This has been provided as part of the SMAT/MATS data set, pre

- calculated by EPA. The formula used for retained nitrate is shown below, as given in the EPA Modeling Guidance:

 Calculate quarterly averages of non

- dependent species . Averages for nitrate, sulfate, carbons, other primary PM 2.5 (OPP), and concurrent FRM values are calcu lated. Quarterly averages for measu red organic carbon are used for comparison to an organic carbon minimum (or OC floor ). Quarterly averages for DON are also calculated for use in

the retained ammonium calculation.

 Calculate quarterly averages of retaine d ammonium (NH4

r ) . Averages for retained ammonium are calculated from quarterly sulfate, nitrate, and DON averages. The formula is given below, as given in the EPA Modeling Guidance:

19 Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Qu ality Goals for Ozone, PM

2.5 , and Regional Haze , EPA, April 2007.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 42

 Calculate quarterly averages of par ticle bound water (PBW) . Averages for PBW are calculated from quarterly sulfate, retained nitrate, and indirect ammonium averages. The formula is given below for low acidity (DON >= 0.225), as given in the MATS User’s

Guide:

S = SO4 / (SO4 + NO3r + NH4 r) N = NO3r / (SO4 + NO3r + NH4r) A = NH4r / (SO4 + NO3r + NH4r)

PBW = {202048.975

- 391494.647 *S

- 390912.147 *N + 442.435 *(S**1.5)

- 155.335 *(N**1.5)

- 293406.827 *(A**1.5) + 189277.519 *(S**2)

+ 377992.610 *N*S + 188636.790 *(N**2)

- 447.123 *(S**2.5)

- 507.157 *(S**1.5)*N

- 12.794 *(S**3) + 146.221 *(N**1.5)*S

+ 217.197 *(N**2.5) + 29.981 *(N**1.5)*(S**1.5)

- 18.649 *(N**3)

+ 216266.951 *(A**1.5)*S + 215419.876 *(A**1.5)*N

- 621.843 *(A**1.5)*(S**1.5) + 239.132 *(A**1.5)*(N**1.5)

+ 95413.122 *(A**3)} * (SO4+NO3r+NH4r)

 Calculate quarterly averages of organic carbon mass by mass balance (OCM mb ). Averages for OCM mb are calculated from the concurrent FRM quarterly averages minus the sum of the other species. This accounts for material associated with organics and/or uncertainties in the measured species. The calculat ed organic mass is compared to the

OC floor to ensure that the mass balance method does not lead to lower concentrations than

measured.

 Calculate quarterly species compositions; apply to weighted quarterly FRM averages. This is done by calculating fractio ns of the total (minus 0.5 passive blank mass) by

individual species

. For this step, the data i s calculated twice to examine results by both total and by regional and local species. The species fractions are then applied to the weighted FRM values.

 Calc ulate quarterly Relative Response Factors (RRFs) from modeling. D irect RRFs are

calculated from baseline and future CAMx modeled impacts for sulfate, nitrate, total organic aerosol (TOA) , elemental carbon, and unspeciated PM 2.5

. For the total and regiona l/local options, this step i s done twice. NH4

r = DON*SO4 + 0.29*NO3

rLiberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 43

 Calculate future quarterly species averages from RRFs, re

- calculate ammonium and

PBW. The RRFs reduce the sulfate, nitrate, carbons, and OPP from the weighted baseline

case values. Future case ammonium and PBW i s calculated from the new quarterly

averages. This step i s performed twice to examine by both total and by regional and local species.

 Calculate the future design value. This is done by adding the future case species by quarter (plus 0.5 blank) and aver aging the quarterly future FRM values, rounded to the nearest tenth for comparison to the annual standard. For an area with strong concentration gradients such as Liberty

- Clairton, ACHD followed EPA Modeling Guidance by using a one

- cell (single

- site) anal ysis in place of a spatially

- averaged array for the design values at Liberty and Clairton.



### 6.3 24

- Hour Attainment Test Methodology

The Speciated Modeled Attainment Test (SMAT) for the 24

- hour standard uses the same methodology as the annual standard for reco nstruction of species and RRFs. But, modeled and observed concentrations are based on specific high day averages instead of quarterly averages.

 Indentify observed (monitored) high days in baseline timeframe . This is done by selecting the 8 highest day s in each quarter over the 200 5

- 200 9 timeframe

. (For Clairton,

due to the 1

- in

- 6 sampling schedule, only the 3 highest days per quarter were used.) This method focuses on high days that represent se asonal highs rather than overall maximums.

 Calculate qua rterly species compositions for speciation high days . This is done using the same technique as the annual species compositions, but the quarterly averages are based on the highest 10 % (3 samples were used per quarter ) of speciation samples by overall

conc entration.

 Calculate weighted species compositions for baseline high days . This is done by using the quarterly species fra ctions for each of the high observed days. The end results are high day compositions per quarter for each year ( 2005

- 200 9 ). Simila r to the annual test, this step i s done twice to examine the results by total and regional/local options.

 Calculate quarterly Relative Response Factors (RRFs) for high days from modeling. The high modeled days are identifi ed after summing all components. Regional OPP is

ex c luded from the total in this ranking method , due to overestimation of the modeled

OPP. 20 The top 10 % ( 10 days) by quarter are then averaged for sulfate, nitrate, carbons,

and OPP. RRFs are calculated from the baseline and future model ed results. For the total and regional/local options, this step is done twice.

 Calculate future high days from RRFs; re

- calculate ammonium and PBW for each future high day. Using the same methodology as the annual test, high day species are reduced

for the future case by the quarterly RRFs, and ammonium and PBW concentrations are

20 This method was used in the Transport Rule (CSAPR) modeling (see References).Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 44

re

- calculated from the future sulfate, nitrates. This step i s performed twice to examine by both total and by regional and local species.

 Calculate future design value. The future projected high days are re

- ranked by year, and

the 98 th

- perce n tile value is identified for each year

. T he weighted 98 th

- percentile average is the average of the 200 5

- 2007 , 200 6

- 200 8 , and 200 7

- 200 9 3

- year averages, rounded to the nearest integer for comparison to the 24

- hour standard.



### 6.4 Annual Attainment Test Results

A summary of the annual design value calculations for Liberty , by total species and by regional/local species, is given in Tables 6

- 1 and 6

- 2 . Spreadsheets showing the expanded design

v alue calculations are given in Appendix H . All compositions and design values are given in μg/m3, while RRFs are dimensionless ratios.

For the regional/local split option, local modeled carbons and unspeciated PM 2.5 (OTHER) were summed as local primary material (LPM) and re

- apportioned based on monitored compositions. This method better accounts for local primary modeled PM 2.5 that may be overestimated as crustal component.

Table 6

- 1 . Liberty Annual Attainment Test, by Total Species

Baseline 2007 Quarterly Compositions

QTR FRMw Blank Non

- Blank OCMmb EC SO4 NO3r OPP NH4r PBWcalc

1Q 14.637 0.500 14.137 3.814 1.508 3.793 1.352 0.679 1.765 1.227

2Q 18.051 0.500 17.551 4.888 2.014 5.336 0.065 0.990 1.962 2.295

3Q 22.600 0.500 22.100 4.689 2.262 8.018 0.000 0.966 2.721 3.444

4Q 18.186 0.500 17.686 5.647 2.631 4.426 0.545 0.789 1.753 1.894

AVG 18. 4

RRFs

QTR TOA EC SO4 NO3 O THER

1Q 0.804 0.501 0.690 0.893 0.851

2Q 0.746 0.531 0.500 0.956 0.827

3Q 0.721 0.545 0.450 1.304 0.816

4Q 0.817 0.513 0.605 0.766 0.830

Future 2014 Quarterly Compositions

QTR FRMf Blank Non

- Blank OCMmb EC SO4 NO3r OPP NH4r PBWcalc

1Q 10.850 0.500 10.350 3.067 0.756 2.618 1.208 0.578 1.298 0.825

2Q 10.900 0.500 10.400 3.647 1.069 2.667 0.062 0.819 0.989 1.146

3Q 12.280 0.500 11.780 3.382 1.233 3.604 0.000 0.789 1.223 1.548

4Q 12.440 0.500 11.940 4.611 1.350 2.679 0.417 0.655 1.086 1.141

AVG 11.6Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 45

Table 6

- 2 . Liberty Annual Attainment Test, by Regional/Local Species

Baseline 2007 Quarterly Compositions, Local

QTR OCMmb EC SO4 NO3r OPP NH4r PBWcalc

1Q 0.821 0.904 0.881 0.124 0.284 0.445 0.329

2Q 1.273 1.370 0.480 0.014 0.297 0.329 0.299

3Q 0.000 1.548 0.960 0.000 0.372 0.554 0.803

4Q 2.756 1.993 1.698 0.000 0.413 0.625 0.765

Local RRFs

QTR TOA EC SO4 NO3 OTHER

1Q 0.811 0.811 0.821 1.209 0.811

2Q 0.837 0.837 0.851 1.815 0.837

3Q 0.827 0.814 0.802 2.396 0.814

4Q 0.800 0.800 0.802 1.379 0.800

Baseline 2007 Quarterly Compositions, Regional

QTR OCMmb EC SO4 NO3r OPP NH4r PBWcalc

1Q 2.993 0.604 2.912 1.228 0.395 1.319 0.898

2Q 3.615 0.644 4.857 0.051 0.693 1.633 1.996

3Q 4.689 0.714 7.058 0.000 0.594 2.168 2.641

4Q 2.892 0.638 2.728 0.545 0.376 1.128 1.129

Regional RRFs

QTR TOA EC SO4 NO3 OTHER

1Q 0.798 0.437 0.674 0.891 0.878

2Q 0.704 0.386 0.470 0.939 0.849

3Q 0.665 0.394 0.420 1.264 0.858

4Q 0.811 0.434 0.581 0.761 0.860

Future 2014 Quarterly Compositions, Combined Regional and Local

QTR FRMf Blank Non

- Blank OCMmb EC SO4 NO3r OPP NH4r PBWcalc

1Q 11.236 0.500 10.736 3.054 0.997 2.686 1.244 0.577 1.333 0.846

2Q 11.265 0.500 10.765 3.610 1.397 2.690 0.074 0.837 1.001 1.156

3Q 12.576 0.500 12.076 3.119 1.541 3.733 0.000 0.812 1.267 1.603

4Q 13.377 0.500 12.877 4.550 1.872 2.946 0.415 0.654 1.182 1.258

AVG 12.1

The Liberty annual attainment tests project a design value range of 11.6

- 12.1 μg/m3, below the standard of 15.0 μg/m3.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 46

A summary of the annual design value calculations for Clairton is given in Tables 6

- 3 and 6

- 4

. Spreadsheets showing the expanded design value calculations are given in Appendix H . All compositions and design values are given in μg/m3, while RRFs are dimensionless ratios.

Table 6

- 3 . Clairton Annua l Attainment Test, by Total Species

Baseline 2007 Quarterly Compositions

QTR FRMw Blank Non

- Blank OCMmb EC SO4 NO3r OPP NH4r PBWcalc

1Q 12.489 0.500 11.989 3.234 1.279 3.216 1.146 0.576 1.496 1.040

2Q 12.797 0.500 12.297 3.425 1.411 3.739 0.046 0.694 1.375 1.608

3Q 19.594 0.500 19.094 4.051 1.954 6.927 0.000 0.835 2.351 2.976

4Q 12.261 0.500 11.761 3.755 1.750 2.943 0.362 0.525 1.166 1.260

AVG 14. 3

RRFs

QTR TOA EC SO4 NO3 OTHER

1Q 0.776 0.507 0.681 0.897 0.815

2Q 0.730 0.578 0.499 0.934 0.763

3Q 0.706 0.590 0.445 1.340 0.753

4Q 0.787 0.512 0.594 0.760 0.815

Future 2014 Quarterly Compositions

QTR FRMf Blank Non

- Blank OCMmb EC SO4 NO3r OPP NH4r PBWcalc

1Q 9.123 0.500 8.623 2.509 0.648 2.189 1.029 0.469 1.091 0.689

2Q 7.747 0.500 7.247 2.500 0.815 1.866 0.043 0.530 0.692 0.802

3Q 10.596 0.500 10.096 2.860 1.153 3.084 0.000 0.629 1.047 1.325

4Q 8.258 0.500 7.758 2.954 0.896 1.749 0.276 0.428 0.710 0.745

AVG 8.9Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 47

Table 6

- 4 . Clairton Annual Attainment Test, by Regional/Local Species

Baseline 2007 Quarterly Compositions, Local

QTR OCMmb EC SO4 NO3r OPP NH4r PBWcalc

1Q 0.696 0.767 0.747 0.105 0.241 0.378 0.279

2Q 0.892 0.960 0.336 0.010 0.208 0.230 0.209

3Q 0.000 1.337 0.829 0.000 0.321 0.478 0.693

4Q 1.832 1.326 1.129 0.000 0.275 0.416 0.509

Local RRFs

QTR TOA EC SO4 NO3 OTHER

1Q 0.739 0.739 0.725 1.109 0.739

2Q 0.755 0.755 0.752 1.804 0.755

3Q 0.746 0.735 0.700 2.123 0.735

4Q 0.773 0.773 0.743 1.235 0.773

Baseline 2007 Quarterly Compositions, Regional

QTR OCMmb EC SO4 NO3r OPP NH4r PBWcalc

1Q 2.538 0.512 2.469 1.041 0.335 1.119 0.761

2Q 2.533 0.451 3.403 0.036 0.486 1.144 1.398

3Q 4.051 0.617 6.098 0.000 0.513 1.873 2.282

4Q 1.923 0.424 1.814 0.362 0.250 0.750 0.751

Regional RRFs

QTR TOA EC SO4 NO3 OTHER

1Q 0.769 0.430 0.675 0.895 0.875

2Q 0.685 0.429 0.470 0.918 0.845

3Q 0.653 0.433 0.420 1.309 0.853

4Q 0.779 0.433 0.580 0.756 0.852

Future 2014 Quarterly Compositions, Combined Regional and Local

QTR FRMf Blank Non

- Blank OCMmb EC SO4 NO3r OPP NH4r PBWcalc

1Q 9.276 0.500 8.776 2.465 0.787 2.207 1.049 0.471 1.103 0.694

2Q 7.782 0.500 7.282 2.408 0.919 1.852 0.051 0.567 0.689 0.796

3Q 10.621 0.500 10.121 2.644 1.250 3.139 0.000 0.674 1.066 1.349

4Q 8.783 0.500 8.283 2.915 1.208 1.892 0.274 0.425 0.761 0.807

AVG 9.1

The Clairton annual attainment tests project a design value range of 8.9

- 9.1 μg/m3, below the standard of 15.0 μg/m3.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 48



### 6.5 24

- Hour Attainment Test Results

A summary of the 24

- hour design value calculations for Liberty is given in Tables 6

- 5 and 6

- 6

. Spreadsheets showing the expanded design value calculations are given in Appendix H . All compositions and design values are given in μg/m3, while RRFs are dimensionless ratios.

Quarterly species compositions are calculated in a similar manner used in the annual test, but the results are applied to high days for each quarter instead of averages. RRFs are calculated by ratios of the modeled future case to baseline case results for high days. The future case results are then calculated by multiplying th e baseline results by the corresponding RRF by species.

For the regional/local split option, similar to the annual results, local modeled carbons and OPP were summed as local primary material (LPM) and re

- apportioned based on monitored compositions.

Tabl e 6

- 5 . Liberty 24

- Hour Attainment Test, by Total Species

Base line High Days

Base line FRM High Days Year 2005 2006 2007 2008 2009

98th

- Percentile 69.6 55.7 54.7 50.0 45.3

3

- Year Design Values 3

- Year Period Avg

2005

- 2007 60.0

2006

- 2008 53.5

2007

- 2009 50.0

5

- Year Weighted Average 5

- Year Period Avg

2005

- 2009 54

RRFs

QTR TOA EC SO4 NO3 OTHER

1Q 0.796 0.485 0.712 0.963 0.815

2Q 0.824 0.614 0.402 4.326 0.807

3Q 0.795 0.678 0.334 2.600 0.920

4Q 0.820 0.467 0.610 0.767 0.830

Future High Days

Future Projected FRM High Days Year Year 1 Year 2 Year 3 Year 4 Year 5

98th

- Percentile 41.5 35.6 32.0 31.7 31.1

3

- Year Design Values 3

- Year Period Avg

Years 1

- 3 36.4

Years 2

- 4 33.1

Years 3

- 5 31.6

5

- Year Weighted Average 5

- Year Period Avg

Years 1

- 5 34Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 49

Table 6

- 6 . Liberty 24

- Hour Attainment Test, by Regional/Local Species

Baseline High Days

Baseline FRM High Days Year 2005 2006 2007 2008 2009

98th

- Percentile 69.6 55.7 54.7 50.0 45.3

3

- Year Design Values 3

- Year Period Avg

2005

- 2007 60.0

2006

- 2008 53.5

2007

- 2009 50.0

5

- Year Weighted Average 5

- Year Period Avg

2005

- 2009 54

Local RRFs

QTR TOA EC SO4 NO3 OTHER

1Q 0.751 0.751 0.781 1.419 0.751

2Q 0.811 0.811 0.806 2.278 0.811

3Q 0.956 0.956 0.874 7.379 0.956

4Q 0.751 0.751 0.784 1.226 0.751

Regional RRFs

QTR TOA EC SO4 NO3 OTHER

1Q 0.789 0.410 0.702 0.956 0.864

2Q 0.788 0.436 0.365 4.749 0.860

3Q 0.721 0.484 0.295 2.401 0.898

4Q 0.818 0.420 0.587 0.761 0.869

Future High Days, Combined Regional and Local

Future Projected FRM High Days Year Year 1 Year 2 Year 3 Year 4 Year 5

98th

- Percentile 42.9 36.8 34.0 32.8 32.9

3

- Year Design Values 3

- Year Period Avg

Years 1

- 3 37.9

Years 2

- 4 34.5

Years 3

- 5 33.2

5

- Year Weighted Average 5

- Year Period Avg

Years 1

- 5 35

The Liberty 24

- hour attainment tests proje ct a design value range of 34

- 35 μg/m3, within the standard of 35 μg/m3.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 50

A summary of the 24

- hour design value calculations for Clairton is given in Tables 6

- 7 to 6

- 8. Spreadsheets showing the expanded design value calculations are given in Appendix H . All compositions and design values are given in μg/m3, while RRFs are dimensionless ratios.

Table 6

- 7 . Clairton 24

- Hour Attainment Test, by Total Species

Baseline High Days

Baseline FRM High Days Year 2005 2006 2007 2008 2009

98th

- Percentile 30.9 35.8 35.0 34.6 25.9

3

- Year Design Values 3

- Year Period Avg

2005

- 2007 33.9

2006

- 2008 35.1

2007

- 2009 31.8

5

- Year Weighted Average 5

- Year Period Avg

2005

- 2009 34

RRFs

QTR TOA EC SO4 NO3 OTHER

1Q 0.803 0.519 0.712 1.123 0.749

2Q 0.800 0.668 0.395 2.445 0.848

3Q 0.752 0.719 0.350 1.052 0.814

4Q 0.827 0.512 0.601 0.799 0.803

Future High Days

Future Projected FRM High Days Year Year 1 Year 2 Year 3 Year 4 Year 5

98th

- Percentile 17.6 19.2 17.4 20.2 14.8

3

- Year Design Values 3

- Year Period Avg

Years 1

- 3 18.1

Years 2

- 4 18.9

Years 3

- 5 17.5

5

- Year Weighted Average 5

- Year Period Avg

Years 1

- 5 18Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 51

Table 6

- 8 . Clairton 24

- Hour Attainment Test, by Regional/Local Species

Baseline High Days

Baseline FRM High Days Year 2005 2006 2007 2008 2009

98th

- Percentile 30.9 35.8 35.0 34.6 25.9

3

- Year Design Values 3

- Year Period Avg

2005

- 2007 33.9

2006

- 2008 35.1

2007

- 2009 31.8

5

- Year Weighted Average 5

- Year Period Avg

2005

- 2009 34

Local RRFs

QTR TOA EC SO4 NO3 OTHER

1Q 0.650 0.650 0.674 1.175 0.650

2Q 0.900 0.900 0.862 1.979 0.900

3Q 0.914 0.914 0.852 1.494 0.914

4Q 0.679 0.679 0.687 1.291 0.679

Regional RRFs

QTR TOA EC SO4 NO3 OTHER

1Q 0.801 0.424 0.725 1.121 0.927

2Q 0.664 0.401 0.293 2.487 0.804

3Q 0.541 0.365 0.288 1.035 0.669

4Q 0.826 0.438 0.588 0.793 0.889

Future High Days, Combined Regional and Local

Future Projected FRM High Days Year Year 1 Year 2 Year 3 Year 4 Year 5

98th

- Percentile 17.3 19.1 17.7 20.5 14.5

3

- Year Design Values 3

- Year Period Avg

Years 1

- 3 18.0

Years 2

- 4 19.1

Years 3

- 5 17.5

5

- Year Weighted Average 5

- Year Period Avg

Years 1

- 5 18

The Clairton 24

- hour attainment tests project a design value of 18 μg/m3, below the standard of 35 μg/m3.

Weight of evidence, as given in Section 9 , provides additional assertions that the Liberty

Clairton area will demonstrate attainment of the NAAQS.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 52



### 6.6 Unmonitored Area Analysis

T he EPA Modeling Guidance recommends examination of “unmonitored” areas for possible future exceedances of the NAAQS standards by employing a combination of interpolated

monitored and modeled relative response ratios within spatial fields across the area.

The Liberty and Clairton Monitors are part of a complete network for Allegheny County

– according to monitoring network guidance 21

, there are no “unmonitored” areas. However, for a more complete analy sis, ENVIRON generated grid concentrations using EPA’s MATS program for 0.8 km grid cells surrounding and in between the Liberty and Clairton sites. ENVIRON applied MATS using its u nmonitored a rea a nalysis feature to “ spatially interpolate current year

an nual PM 2.5 design value concentrations and project 2014 annual PM 2.5 future design value concentrations throughout the 0.8 km and 4 km modeling domains using the CAMx 0.8 and 4 km modeling results, respectively. ”

The analysis showed that no 0.8 km grid ce ll in the Liberty

- Clairton a rea contained projected design values above the NAAQS. Details of the unmonitored analysis are given in Appendix G

3

.

21 EPA PM 2.5 monitoring policy and guidance: http://www.epa.gov/ttnamti1/pmpolgud.htmlLiberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 53



## 7 Reasonably Available Control Technology and Measures

Reasonably Available Control Technology (RACT) and R easonably A vailable C ontrol M easures (RACM) for each PM 2.5 nonattainment area require a demonstration that the agency has adopted all reasonably available control measures, including RACT for stationary sources, necessary to demonstrate attainment as expeditiously as practicable

.

In determining whether a particular emission reduct ion measure or set of measures must be adopted as RACM, the agency must consider the cumulative impact of implementing the available measures. Potential measures that are reasonably available considering technical and economic feasibility must be adopted as RACM if, considered collectively, they would advance the attainment date by one year or more.

The sole purpose of this RACT/RACM analysis is to determine if additional reasonable controls are available that could advance the attainment date by one ye ar. These reviews should not and cannot be used by any source to satisfy any RACT analysis required by that source in a present or future permitting project.

Primary PM 2.5 is the pollutant of concern in the Liberty

- Clairton nonattainment area and was the

focus of the RACT/RACM analysis. P recursors SO 2 and NO

x were also reviewed for specific RACM options

. Key RACT/RACM f indings are included in this section, with further details of this analysis found in Appendix I

.

RACT at U. S. Steel Mon Valley Works

– Clairton Plant and Alternatives Considered

The U. S. Steel Clairton Plant is the largest source of PM 2.5 located within the Liberty

- Clairton area. Both U. S. Steel and ACHD separately reviewed the PM 2.5 emissions units for the facility

and found them to be satisfactor y for this RACM demonstration.

As part of the Clairton Plant installation permit application for C Battery, U. S. Steel performed a Best Available Control Technology (BACT) analysis for all the affected emission units. The Clairton Plant batteries are of the conventional by

- product cok e oven type. The new installation of Battery C with the PROven system was determined to be BACT at the time. An alternative option of non

- by

- product recovery coke ovens using the Sun Coke Co. process and electric power generation was not considered techn ically feasible for integration into the other portions of the by

- product coke oven plant.

The coke oven batteries 7, 8, and 9 were shut down in 2009. Coke oven batteries 1

- 3, 13

- 15, 19

- 20, and B have some of the nation’s strictest standards, either as ACHD Article XXI regulations or as permit conditions, so there were few alternatives to operational controls to be considered. Appendix I contains a detailed list of the controls by process.

For the new Quench Towers C, 5A, and 7A, double baffles are RAC T versus alternative shorter quench towers with single baffles. Coke dry quenching (CDQ) was considered but found unacceptable for this project due to available space and cost. This was the same conclusion onLiberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 54

the other remaining quench towers. Other opt ions were reviewed but would required extensive construction and installation costs. Included in this review were a “wet Low Emission Quench (LEQ),” a “ThyssenKrupp EnCoke World Steel, Bochum Coke Stabilization Quenching (CSQ) process,” a “Kress Indirect Cooling (KIDC) system,” and others.

Alternatives to such pushing emissions control are the use of a coke side shed enclosure vented to a control device or a mobile capture and control unit. However, the shed system is too costly and the mobile capture i s not technically feasible for this SIP. For battery process upsets, the atmospheric venting of raw coke oven gas through by

- pass/bleeder stacks is first passed through a flare system. The alternatives to this are to use either regenerative thermal oxida tion or catalytic thermal oxidation; however, these alternatives are too costly to be feasible for this SIP. Similarly, the impacts from the emissions of Boiler #1, Boiler #2, R1 Boiler, R2 Boiler, T1 Boiler, T2 Boiler, and the Desulfurization Plant After burner do not warrant additional control.

RACT at Koppers Industries, Inc. and Alternatives Considered

Koppers Industries, Inc. Clairton P lant is a chemical processing plant where crude coal tar is debenzolized and distilled into pitch and various other products such as creosote, carbon black oil, and refined chemical oil.

For the tar refining process, gases from the fume vents, pressure reliefs, ejectors, chiller, and condensate separator are manifolded together and burned in the eight process heaters . As alternative controls, the fumes could be flared or catalytically oxidized

– but neither of the two alternatives would result in added emission reductions. Flaring would be less efficient and catalytic oxidation is more costly, so they are unacceptab le alternatives.

When manufacturing the rod pitch, the process utilizes a pitch cooler and dryer. A low temperature pulse

-

jet baghouse is used to control particulate emissions from the two units. As an alternative, a wet scrubber could be utilized, but there would be an undesirable wastewater disposal problem without gaining any emission reduction advantage.

RACT at Mid Continent Coal and Coke Co. and Alternatives Considered

Mid

- Continent Coal and Coke Company is a metallurgical coke breeze screening unit, serving

the U. S. Steel Clairton Plant. Total PM 2.5 emissions from this plant are less than 1 to 5 tons per year from all sources, including roads. No combination of sources that include this plant would advance attainment by a year.

The only emi ssions of interest from this plant are unpaved roadways. As alternatives, the roadway areas could have dust suppressant or watering; however, the emission reduction benefit

from these alternatives is minimal because the amounts are small from the onset an d the grounds tend to retain significant moisture.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 55

RACT at Dura

- Bond Coating Company and Alternative Considered

Dura

- Bond Coating Company is a specialty coater of steel pipe. The pipe is intended for underground installation and is designed to withsta nd many years of use. The coating protects the steel pipe from moisture, thermal expansion, and other stresses. Total PM 2.5 emissions from this plant are 1 to 5 tons per year from all sources.

RACT for this facility is: baghouses for powder coating line P001 shot blast pipe cleaners, powder reclaimer for powder coating operation PE1, baghouse for extruded polyethylene coating (X

- Tec) line P003, gasoline storage tank conservation vent, watering roadways to limit road dust emissions, and catalytic retrofit and spark adjustment for forklifts. Since these RACT options are being implemented, no combination of sources that include this plant would advance attainment by a year. No additional RACT were considered for this facility.

RACT at Pennsylvania Electri c Coil and Alternative Considered

Pennsylvania Electric Coil manufactures high voltage stator coils, up to 15Kv, as well as rotor, armature, field coils, and brake, magnet and specialty coils. The facility also repairs, rewinds,

and remanufactures AC/DC motors, generators, and other types of apparatus, in shop or on site.

Total PM 2.5 emissions from this plant are less than one ton per year from all sources.

RACT for this facility is: integral afterburners for the burn

- off ovens, cover for Safety

- Kleen

pa rts cleaner, cyclone used for the abrasive blasting operation, paint booth filters, baghouse for the tinning process, conservation vents for storage areas/tanks, and opacity monitoring for various processes. Since these RACT options are being implemented, no combination of sources that include this plant would advance attainment by a year. No additional RACT were considered for this facility.

RACT at Mon Valley Transportation Center, Inc. and Alternatives Considered

The Mon Valley Transportation Center , Inc. facility in Glassport, PA operates as a coal, coke and aggregate transshipment and storage facility. Total PM 2.5 emissions from this plant are less than one ton per year from all sources.

RACT for this facility is: barge loader #2 water sprayer, r ailcar unloader water sprayer, covered conveyors, drop sleeves, catalytic retrofits and spark adjustments for diesel

- fuel vehicles, watering storage piles, and watering and/or using dust suppressants on unpaved roadways. Since these RACT options are being implemented, no combination of sources that include this plant would advance attainment by a year. No additional RACT were considered for this facility.

RACT at AKJ Clairton LLC and Alternatives Considered

The AKJ Clairton plant is a sludge mixing oper ation facility that uses coal tar decanter sludge

from the U . S. Steel Clairton Plant and different liquid diluents and a dispersant in a batch operation to produce liquefied coal waste sludge for re

- use. PM 2.5 emissions from this facility are negligible (less than 0.1 ton per year)

.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 56

RACT at Tech Met, Inc. and Alternatives Considered

Tech Met provides chemical milling services to a variety of aerospace, medical, and industrial

customers. Total PM 2.5 emissions from this plant are less than 1 to 5 tons per year from all sources, including roads. No combination of sources that include this plant would advance attainment by a year.

RACM at Nonpoint Sources

TranSystems|E.H. Pechan (TS|Pechan), along wi th KB Environmental Sciences, Inc., examined

RACT/RACM seve ral RACM options for area, nonr o a d, and mobile sources in the Liberty

Clairton area. RACT /RACM and alternatives for point and nonpoint sources are summarized in

Table 7

- 1 below. Additional detail s of the RACT/RACM analysis can be found in Appendix I

.

Table 7

- 1 . RACT/ RACM and Alternatives Considered for the Liberty

- Clairton Area

Source Reasonably

Available Control

Measure Alternative(s)

Considered Remarks

U.S. Steel New Batteries and

Quench Towers No

Koppers Industries,

Inc. 1) For tar refining,

fumes are burned for process heat. 2) For making rod pitch, a cooler/dryer and baghouse used. Flaring or catalytic oxidation, and wet scrubber, respectively. Flaring less efficient,

catalytic oxidation more costly, and

scrubber creates wastewater problem.

Mid Continental

Coal and Coke Company Negligible PM

emissions overall. Roadway watering Grounds inherently

retain water.

Dura

- Bond Coating

Com pany Negligible PM

emissions. RACT is baghouse, powder reclaimer, storage

tank conservation vent, road watering. No

Pennsylvania

Electric Coil Negligible PM

emissions. RACT is afterburners, cover for cleaner, cyclone, paint booth filters, baghouse stora ge tanks conservation vents, and opacity monitoring. NoLiberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 57

Source Reasonably

Available Control

Measure Alternative(s)

Considered Remarks

Mon Valley Transportation
Center, Inc. Negligible PM

emissions. RACT is water sprayers for loaders/unloader, covered conveyors,

diesel vehicle retrofits, water dust

suppressant. No

AKJ Clairton, LLC Negligible PM

emissions. No

Tech Met, Inc. Negligible PM

emissions. No

Restaurants

– commercial charbroiling Currently no RACM. Rules to require

charbroiler exhaust stack catalytic

oxidizer s for chain driven broilers, and

HEPA filters for

under

- fired broilers. Full implementation

could take five (5)

years.

Residential Wood Burning

– stoves and fireplaces Currently no RACM. Woodstove exchange program, education & outreach on burning clean, curtailment of burning with expected high ambient le vels of PM, and replacement

of old stoves when

homes are sold. Options 1 and 3 have

quantifiable emissions reductions,

but time to implement is longer than needed. Option

2 is difficult to quantify and Option 4 does not generate significant

reductions.

R esidential Wood Burning

– Wood

fired boilers. Currently no RACM. Compliance with state OWB regulation and curtailment of burning with expected high

ambient levels of PM. Option 1 does not

produce significant emissions reductions,

and time to implement Opti on 2 is longer than

needed.

Residential Coal

Furnaces Currently no RACM. Replace coal furnaces with natural gas or electric systems. Coal furnace

emissions are negligible.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 58

Source Reasonably

Available Control

Measure Alternative(s)

Considered Remarks

Four Stroke Gasoline

Lawnmowers Currently no RACM. Gas for Electric mower trade program, Upgrade mower engine to higher Tier standards, native landscaping, and

reduced commercial mowing. Extremely small

reductions for trading programs and commercial mowing reductions, and unquantifiable

reductions from

nat ive landscaping.

Commercial

Gasoline Leaf

Blowers Currently no RACM. Gas for Electric trade

program. Extremely small

emissions reductions.

Commercial and

Residential Gasoline

Snowblowers. Currently no RACM. Gas for Electric trade

program. Extremely small

emissions reductions.

On

- road mobile

sources Currently no RACM. Diesel engine retrofits, expanded use of clean fuel, replacement of public or private fleets ahead

of normal schedule.

Diesel Powered

Construction Equipment Idling restrictions in

effect. Diesel engine retrofits

and engine replacement with higher Tier engine. Cost of emission

reductions can be expensive and relatively small total

reductions.

Non

- road Gasoline

and Diesel equipment and

vehicles Currently no RACM. Expand the use of

clean bur ning B20

and E10. Relatively small

reductions.

Off

- road Diesel Equipment Currently no RACM. Emissions testing & repair/maintenance program, and roadside

anti

- smoke inspections. There is not

sufficient time to implement programs.

Recreational Marine

Boats Currently no RACM. Reduce emissions or

accelerate retirement of high emitting boats. Recreational boats

are insignificant

source in L

- C area.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 59

Source Reasonably

Available Control

Measure Alternative(s)

Considered Remarks

Diesel Powered

Short

- haul and Long

haul Trucks Currently no RACM. Diesel retrofits or engine replacement, compliance with idling law, and emission/opacity testing.

Diesel Switcher

Locomotives Currently no RACM. Locomotive retrofit

with Idle Reduction Technologies

– APU’s. Replacement with

new switchers. Relatively low

emission reduction

for APUs. Cost is an

issue for replacements.

Diesel Line

- Haul

Locomotives Currently no RACM. Replacement of pre

Tier 0 and Tier 0 engines with Tier 2.

Accelerated replacement with Tier

4 locomotives. First option

– high

cost. Second option has low impact because engines

oper ate outside

NAA.

Commercial Marine

Vessels Currently no RACM. Repowering from Tier 0 to Tier 2 engines. Retrofit tugboats with diesel particulate filters. Control idling. Idling restrictions are

not workable since tugs are constantly deployed.

In summary, emission reductions needed to reach attainment in Liberty

- Clairton are dependent primarily on shutdowns and modifications at the U. S. Steel Mon Valley Works

– Clairton Plant. The proposed new configuration at the Clairton Plant will lead to a reduction of 284 tons per year, and the new equipment has already engaged reasonably or best available control technology. The projected Liberty

- Clairton area beyond the Clairton Plant will total less than 62 tons per year of primary PM 2.5

.

The finding of this analysis is that the identified RACM s ( or combination thereof ) for the Liberty

- Clairton PM 2.5 nonattainment area are not likely to advance the attainment date by one

year or more. ACHD has, therefore, adopted RACT and RACM as defined for this PM 2. 5 SIP.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 60



## 8 Contingency Measures

As outlined in the PM 2.5 I mplementation G uidance

, 22 PM 2.5 contingency measures are additional control measures to be implemented in the event that an area fails to meet Reasonable Further Progress (RFP) or fails to attain the standards by its attainment date. RFP documentation is not required for this SIP since an extension of attainment date is not necessitated.

This attainment demonstration is based on a baseline year of 2007, with an attainment year of

2014

. Thus, the time period for the projected reductions is 7 years. Contingency measures are

recommended to be based on approximately one year of additional emissions reduction

.

The majority of reductions that are pertinent within the Liberty

- Clairton area involve direct

PM 2.5 emissions. The reduction in PM 2.5 f o r all source categories is 290.9 tons, as shown below

in Table 8

- 1 . While reductions of PM 2.5 precursors are also projected

, the size of the Liberty

Clairton area and nature of the localized excess necessitates reduction of the direct PM 2.5 more so than the precursors.

Table 8

- 1

. Calculation of Required and Excess Emission Reductions

Liberty

- Clairton Area PM 2.5 (tons/year )

Baseline (2007) Liberty

- Clairton Area

Emissions 997.8

Projected (2014) Liberty

- Clairton Area

Emissions 706.8

Change in Emissions

- 290.9

Target Reductions for Contingency

Measures (1/ 7 ) 4 1.6

EPA I mplementation G uidance states that contingency measures should consist of other control measures for the area that are not included in the control strategy for the SIP. This could include federal measures and local measures already scheduled for implementation, along with measures

to be implemented if attainment is not achieved.

Should attainment not be achieved by December 2014, the consent order and agreement with U.S. Steel (as amended in September 2010 and July 2011 ) specifies the following: c oke oven wall rebuilds for Battery 20 t o be implemented in late 2014. U. S. Steel will replace 88 heating walls by October 31, 2014, and the battery will meet its opacity limits by December 31, 2014, including an advanced patching plan and a revitalization plan of the battery heating system, as

22 Federal Register, Vol. 72, No. 79, Pages 20642

- 3, and EPA March 2, 2012 Memo from S. D. Page

.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 61

necessary. Emissions reduced by the improvements to Battery 20 are expected to be 10.8 tons/year.

Therefore, a minimum of an additional 30.8 tons/year reduction is required. To attain this reduction, the consent order and agreement with U. S. Steel ( to be amended by Dec. 31, 2013 ) specifies the following: within 18 months after receiving notice from ACHD that EPA is requiring implementation of the contingency measures, U. S. Steel’s Clairton Plant will reduce emissions from the current Quench Tower 1 by 30.8 tons from emissions in the 20 14 attainment

demonstration inventory as modeled in this SIP; or implement emission reductions greater than or equal to 30.8 tons per year (unless a lesser amount is needed to demonstrate attainment of the

2006 24

- hour PM 2.5 NAAQS).

Total emissions reductions from the contingency measures are given in Table 8

- 2

.

Table 8

- 2 . Contingency Measures Emission Reductions

Process PM 2.5 2014

Modeled

Emissions Value (tons/year) PM 2.5

Contingency Value (tons/year) PM 2.5 Reduction

(Inventory

– Contingency) Value (tons/year)

Battery 20

– Rebuilds,

Combustion Stack 21.1 11.3 9.8

Battery 20

– Rebuilds,

Door Leaks 2.1 1.1 1.0

Quench Tower 1 65.5 34.7 30.8

Totals 88.7 47.1 41.6

The emissions reductions due to the contingency measures would be equal to 1 year’s worth of emissions reductions required by the attainment demonstration; t herefore, the identified

reductions satisf

y the requirement for contingency measures.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 62



## 9 Weight of Evidence

EPA’s Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for Ozone, PM 2.5 , and Regional Haze (2007) encourages the use of corroboratory analyses to support the modeled attainment demonstration. These analyses, collectively referred to as “weight of evidence” (WOE), help bolster the assertions that an area will achieve

attainment in the allotted time.



### 9.1 Liberty

- Clairton Monitored Data Trends

Allegheny County sites have shown decreasing trends for PM 2.5 since 2000 (see Figure s 2

- 3 and

2

- 4 ). Figure s 9

- 1 and 9

- 2 show annual and 24

- hour design values for the Liberty and Clairton

monitors over a 10

- ye ar timeframe, with linear regression trend lines extrapolating data to 2014 (i.e., design value s for 2012

- 2014).

Figure 9

- 1

. Liberty and Clairton FRM Annual Design Values, with Trend Lines Extrapolated to

2014Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 63

Figure 9

- 2

. Liberty and Clairton FRM 24

- Hour Design Values

, with Trend Lines Extrapolated

to 2014

Based on moni tored data alone, Figure s 9

- 1 and 9

- 2 show projected PM 2.5 design values for Liberty and Clairton that are below the standards

. Both sites show a long

- term decline in PM 2.5 concentrations that are statistically significant 23

. These trend lines do not account for any additional influences to future emission levels that are discussed in this SIP, such as the

modifications at the U. S. Steel Mon Valley Works

– Clairton Plant.



### 9.2 Local Major Source Modifications

Major source modifications that were not included i n the modeling demonstration will lead to additional reductions of background and/or direct emissions that affect the Liberty

- Clairton area. These modifications include the following:

 U. S. Steel Mon Valley Works

– E dgar Thomson Plant : U. S. Steel implemented enhanced operating and maintenance plan s and installed upgrades to the Basic Oxygen Process (BOP) operations in 2009

- 2010. Reductions of pollutants due to these controls were not estimated for the modeling demonstration.

23 Based on EPA Region III’s R Analysis of the Liberty Clairton PM 2.5 Area, 2012.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 64

 Bellefield Boiler : The Bellefield plant refueled its coal

- fired boilers to natural gas in

2009 . Emissions reductions due to the fuel switch have been “banked” as emission reduction credits (ERCs) and were not included in the modeling demo nstration.

 Eastman Chemical Resins, Inc. : In Dec ember 2011, Eastman entered into a consent
decree and agreement with the U.S. Dept. of Justice, EPA, and ACHD to install VOC control equipment at its Jefferson Plant . Estimates of pollutant reductions due to these controls were not available for the modeling demonstration.



### 9.3 EGU Deactivations

Effective October 1, 2012, GenOn (now NRG) Energy deactivat ed the four coal

- fired electric generating units (EGUs) located at the Elrama P ower P lant , upwind of the Li berty

- Clairton area

. (A t the time of this SIP submittal, the units were deactivated but not permanently retired. )

Elrama e missions used in the future case modeling w ere based on CSAPR allocations.

Several a dditional coal

- fired units in PA and surrounding states (OH, WV, and MD) were deactivated in 2012 24 but were included in the modeling demonstration at CSAPR emissions

levels

. Table 9

- 1 below provides de tails of the deactivated units.

Table 9

- 1 . EGU Deactivations in 2012 , PA and Surrounding States

Plant Owner/Operator State Unit(s) Capacity (MW)

Elrama GenOn Energy PA 1

- 4 460 Armstrong First Energy PA 1,2 243 Walter C Beckjord Duke Energy OH 1 94

Niles GenOn Energy OH 1,2 217 Bay Shore First Energy OH 2,3,4 495

Eastlake First Energy OH 4,5 837

Conesville AEP OH 3 165 Albright Mon Power WV 1,2,3 283

Willow Island Mon Power WV 1,2 189

R Paul Smith First Energy MD 3,4 115

Additional deactivations are expected in future years due to EPA’s Mercury Air Toxics Standards, increased natural gas production, and/or other factors

. (See Section 5.3.5 for EGU emission projections through mid

- 2015. )

24 PJM Interconnection: http://www.pjm.com/~/media/planning/gen

- retire/generator

- deactivations.ashx (as of Jan. 10, 2013)Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 65



### 9.4 Population Trends

Allegheny County is unique in the fact that the population has been declini ng since the 1960s. Localized regions of population growth are occurring, but the general trend for the county is one of negative growth. T he 2010 census shows continued decrease in population in the five municipalities of the Liberty

- Clairton area as wel l

. According to the U.S. Census Bureau, from 2000 to 2010, the City of Clairton had a decrease in population of about 20%, the largest population decrease in the nonattainment area. (See Figure 9

- 3 below .)

Population decreases were also seen in the remaining nonattai nment area boroughs. Glassport saw a population change of

- 10.2%, Liberty

- 4. 5 %, Lincoln

- 1 2

. 0 %, and Port Vue

- 10. 2 %. In total, the five nonattainment area municipalities decrease d in population by 2,900 people, or

- 13.4% from 2000 to 2 010. This continues a trend of decline of from the 1990

- 2000 period, which saw an average decrease in the nonattainment area of

- 6.6%.

Decreasing populations signal less use of cars and a lesser need fo r school buses and other

diesel

- engine vehicles. Additionally, various consumption activities will d ecline (power use,

water use, etc. )

, and lower amounts of waste will be produced. Combining all of this with the local and national regulations and trends toward more efficient and cleaner cars and fuels, it is expected that PM 2.5 in the nonattainment area will reach levels lower than the models show.

Figure 9

- 3

. Population Trend s for Allegheny County, 2000

- 20 10Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 66



### 9.5 Wood Stoves and Wood

- Fired Boilers

Receptor modeling and source apportionment showed that vegetative burning is a contributor of

PM 2.5 at Liberty. (S ource apportionment results can be found in Appendix C

- 2

. ) Fine particulate pollution producing wood burning stoves and outdoor wood

- fired b oilers are used throughout Allegheny County. Further work in this area, including federal and local regulations addressing

wood

- burning stoves and boilers, respectively, will reduce particulate pollution further in the

nonattainment zone.

9.5.1 Wood Stoves

At the federal level, EPA has promulgated regulations establishing emissions limits for newly

manufactured woodstoves. “EPA

- certified” wood stoves can reduce particulate emissions 70

- 80% per unit compared to an older, non

- certified woodstove. Taking advant age of that, from

2005

- 2007, ACHD participated in EPA’s Great American Wood Stove Changeout Campaign, replacing 176 older non

- EPA certified woodstoves in Southwest Pennsylvania with new, cleaner burning “EPA

- certified” units. According to EPA, changing ou t 20 wood stoves results in a net reduction of 1 ton of particulate matter pollution. While newly manufactured wood stoves have emission controls, older non

- certified stoves continue to pollute the air and could be part of a future wood stove changeout ca mpaign.

Additionally, as of May, 2011, EPA drafted proposed revised New Source Performance Standards (NSPS) for residential wood heaters that will continue to reduce particulate pollution from wood stoves, leading to fewer emissions from future installat ions.

ACHD conducted educational campaigns, covering the health effects and environmental impact of wood smoke, are ongoing. These include campaigns to inform municipalities about pollution from wood stoves, and their ability to curtail it, the availabi lity of cleaner units, and encouraging clean burning practices among those who already own and operate wood stoves.

9.5.2 Outdoor Wood

- Fired Boilers

Outdoor Wood

- Fired Boilers (OWBs), also known as hydronic heaters, are another source of particulate pollution for the Allegheny County and Liberty

- Clairton areas. Over the past five years, a voluntary federal program, a state regulation, and some local ordinances have been established in order to help control OWB generated pollution.

EPA’ Voluntary Hydronic He ater Program, launched in 2007, provides a process for manufacturers to demonstrate that their “Qualified” models are 90 percent cleaner than older unqualified units. At the state level, 25 Pa. Code, Chapter 123.14, “Outdoor wood

- fired boilers”, became e ffective on October 2, 2010, and regulates the use of OWBs in the

Commonwealth. The rule prohibits the sale, purchase, and installation of an OWB unless it is a Phase II qualified OWB. The rule also requires that any new OWB be installed a minimum of

50 feet from the nearest property line, and have a stack that extends at least 10 feet above the ground. There are also requirements that appropriate fuels be used, such as clean, dry wood or wood pellets.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 67

In 2012, ACHD added similar OWB regulations to Article XXI, along with a limited number of health enhancing revisions, including an increased setback requirement of 150 feet, additional stack height criteria, use restrictions on Air Quality Action Days, an d the addition of simple reporting requirements at purchase time. An outreach campaign targeted at OWB manufacturers and distributors is planned to help educate potential buyers of the ACHD regulations they must be in compliance with. ACHD expects this t o help prevent improper burning and excess pollution production.

In addition to the new regulation, Article XXI §2104.01, Visible Emissions, and §2104.04, Odor Emissions, are in place which are useful enforcement tools for managing wood burning stoves

an d boilers. The clean

- burning educational campaigns ongoing at ACHD encourage all Allegheny County residents to consider how and what they burn and how it impacts their health

and environment.

The implementation of the OWB regulation by ACHD, and additiona l work including potential municipal ordinances regulating the use of wood

- burning stoves and OWBs, will reduce particulate pollution further in the nonattainment zones.



### 9.6 Diesel Campaign

ACHD has a robust diesel reduction program that since 2004 has incl uded the implementation of diesel idling regulations affecting school buses, trucks and transit buses, and off

- road

construction

- type vehicles and equipment. The program also has made available nearly $6.6 million in funding for projects involving retrofi tting or repowering of school buses, transit buses,

and locomotive and construction equipment, as well as scientific studies of the extent and location of diesel particulate emissions.

In addition, the efforts of local environmental groups have been signi ficant in developing new city and county laws and regulations, as well as non

- governmental funding of several retrofit

programs.

9.6.1 Idling

Idling regulations are currently in place at the state and c ounty level s

. On October 9, 2008, Act 124, The Pennsylvania Diesel

- Powered Motor Vehicle Idling Act, was signed by Governor Rendell. It became effective on February 6 th , 2009, prohibiting the owners and drivers of any

commercial diesel

- powered on

- road motor vehicle with a gross weight of greater than 10,001 pounds from idling for more than five minutes in any 60

- minute period. Exemptions are in place for the operator’s safety and the comfort of passengers in high or low temperatures. Extensive signage requirements in the law have been integral in sprea ding the news of this new regulation across the state. All truck docks and other places where diesel trucks may park or idle are required to post signs regarding the regulation.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 68

In addition to the coverage of the State Act 124, Allegheny County has passe d and has on the books, effective May 1, 2010, §2105.93 of Article XXI, “In

- Use Off

- Road Diesel Powered Mobile Equipment Engine Idling,” which prohibits idling of off

- road vehicles for more than five consecutive minutes, unless exempt. Operators of such v ehicles can be reported to ACHD and can be fined up to $500 if they are found in non

- compliance. The County regulation primarily affects construction vehicles, which can operate as a nuisance point source at construction sites in highly populated areas. An extensive outreach campaign was conducted by Allegheny County to help owners and managers inform their employees of the regulation to avoid fines and to avoid producing excess pollution.

9.6.2 City Legislation & Industry Initiatives

In 2011, The City of Pitts burgh passed the Clean Air Act of 2011, which required certain publicly subsidized construction projects in Pittsburgh to utilize clean diesel equipment. This legislation will help to reduce diesel particulate pollution from construction projects in the ci ty, both by the direct requirement for retrofitted equipment, and the incentives construction companies now have to retrofit their equipment in advance of securing a contract for a publicly subsidized project, so as to remain competitive. Local nonprofits have begun to work to pass similar legislation covering Allegheny County.

Other similar efforts to address diesel particulate pollution from construction sources have been taken up by local businesses and other organizations. In 2011, The University of Pi ttsburgh Medical Center (UPMC) established language for all future contracts that requires all construction equipment used at any UPMC construction site to meet Tier 4 standards. This requirement went into effect in the spring of 2011, three years before E PA will require Tier 4 standards on all newly manufactured equipment. UPMC currently has several hospitals and other health facilities throughout Allegheny County and is the second largest employer in the

Commonwealth.

9.6.3 ACHD/Heinz Endowment Retrofit Projec t

In 2011, ACHD initiated a project to provide funding to federally

- registered small construction companies to help offset the costs of procuring certified and/or verified diesel retrofit technology . An amount of $925,000 was made available for the const ruction companies to purchase equipment, and ACHD selected the Mid

- Atlantic Regional Air Management Association (MARAMA) to manage the project. A local philanthropic organization, the Heinz Endowments, matched ACHD’s funds and doubled the amount of money for MARAMA to distribute to construction companies in Allegheny County. ACHD’s portion of the funding is to be spent retrofitting equipment in Allegheny County. The Heinz Endowment’s portion will go toward helping construction companies comply with the a bove

- mentioned City of Pittsburgh’s

Clean Air Act of 2011.

Applicants will receive between $10,000 and $100,000 each, if selected. The costs of diesel particulate filters (DPFs) will be covered 100% and companies will receive up to 75% of the cost of engine repowers and rebuilds. ACHD and MARAMA expect somewhere between 15 and 20Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 69

individual companies to receive funding for various pieces of diesel

- engine construction equipment.

9.6.4 Federally Funded Competitive ARRA Clean Diesel Retrofit Projects

The Allegheny County Health Department, with input from the Group Agai nst Smog and Pollution (GASP) and Clean Water Action (CWA) , applied for and was awarded federal funds for projects to reduce diesel particulate pollution in the spring of 2009. A total of $3,498,106 was awarded by the U.S. EPA to the Department and funded four projects to help reduce diesel pollution in Pittsburgh, the Liberty

- Clairton nonattainment area, and throughout Southwestern PA. The money came from the American Recovery and Reinvestment Act (ARRA) via the National Clean Diesel Program. The four p rojects, outlined below, were completed by September 2011.

 The Port Authority of Allegheny County used ARRA funds to assist in replacing two 1996 model year transit buses with cleaner 2010 model

- year diesel hybrid electric buses and to repower nine 2003 m odel year diesel buses with engines that met tighter 2007 emission standards. This project reduces particulate matter pollution by approximately 0.1 tons per year, carbon monoxide by 1.5 tons per year, and nitrogen oxides by 4.8 tons

per year.

 The Constr uctors Association of Western Pennsylvania used ARRA funds to retrofit or repower 39 pieces of heavy

- duty diesel

- powered, non

- road construction equipment in Western Pennsylvania. The various upgrades reduce particulate matter pollution by 9.4

tons per yea r, carbon monoxide by 72 tons per year, hydrocarbons by 11.3 tons per year,

and nitro gen oxides by 69 tons per year.

 Harsco Metals of Americas provides trucking for U. S. Steel. With ARRA funds they installed diesel particulate filters on eight dump truc ks operating in and around U. S. Steel's Mon Valley Works. These trucks are now 90

- percent less polluting than before the project. It is estimated that these diesel particulate filters will remove 0.02 tons of particulate matter per year, 0.20 tons of ca rbon monoxide per year, and 0.03 tons of hydrocarbons per year.

 CSX Transportation used ARRA funds to replace one vintage diesel switcher locomotive

without emission controls with a two

- engine configuration that has the latest in emission

control technolo gy. The GenSet switcher locomotive engine operates at CSX's McKeesport/Demmler rail yard, bringing immediate air quality benefits to the residential neighborhood nearby. The project cuts diesel particulate matter by approximately 0.5 tons per year, carbo n dioxide by 172 tons per year, and nitrogen oxides by 16.6 tons per year. It also saves 15,000 gallons of diesel fuel annually.

9.6.5 State Allocation Diesel Retrofit Project

ACHD also received $433,100 in funding from the Pennsylvania DEP to equip 33 of the City of Pittsburgh’s diesel

- powered refuse haulers with diesel particulate filters. The money came fromLiberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 70

the ARRA via the State Allocation Grant Program. Because of the frequent starting and stopping of the vehicles, and the proximity to all neighborhood s and families in the city, this project significantly helps local air quality. It is estimated that these diesel particulate filters will remove 0.09 tons of particulate matter per year, 0.4 tons of carbon monoxide per year, and 0.1 tons of hydrocarbons per year. The project was completed in June 2010. A previous project led by GASP and Clean Water Action installed diesel particulate filters on 13 other City waste haulers, bringing the total number of diesel particulate filters installed to 46.

9.6.6 ACHD Cle an Air Fund Retrofits

Through its Clean Air Fund, ACHD has completed the retrofit of 85 school buses and 11 pieces of municipal equipment, the latter were all at the City of Clairton. It is estimated that these diesel oxidation catalysts will remove 0.08 tons of particulate matter per year, 1.15 tons of carbon monoxide per year, and 0.42 tons of hydrocarbons per year.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 71



### 9.7 Monitored Data During Low Production Periods

Economic recession in 2009 led to decreased levels of production at many industrial facilities in

Southwest PA. 25 To examine the effect of low production levels on PM 2.5 concentrations, 2009

continuous PM 2.5 (TEOM) and Federal Reference Method (FRM) data were compared to previously monitored data for previous years. Liberty data was comp ared to Lawrenceville data to reveal differences between the regional and localized components. ( Note: TEOM monitors

are not considered “official” PM 2.5 monitors by EPA but can be used for short

- term trends and

for real

- time reporting of data. Data shown here has not b een corrected to make FRM

- like.)

Long

- term hourly averages for the continuous TEOMs are shown in Figure 9

- 4 for Liberty and Lawrenceville during the period of 2000

- 2008. Hours are given according to Eastern Standard Time (EST).

Figure 9

- 4

. Long

- Term Hourly PM 2.5 TEOM Averages at Liberty and Lawrenceville, 2000

- 2008

25 Also note that, in general, much of the Midwest was a bit cooler and wetter than normal in 2009. However, NWS records for Pittsburgh International Airport indicate that closer to the Liberty

- Clairton area, the average annual temperature was near normal and total annual precipitation was near or substantially

below normal in 2009.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 72

Long

- terms trends show that Liberty TEOM concentrations are much higher than Lawrenceville during nighttime hours but are nearly similar during daytime hours (specifically during afternoon to early evening hours). This diurnal trend is due to the strong influence of inversions that lead to the nighttime accumulation of particles in the Liberty

- Clairton area. Smaller peaks c an be seen at Lawrenceville due during peak traffic periods, also possibly influenced by inversions.

Long

- term hourly averages (2000

- 2008) at each site were compared to averages for 2009 data. The Liberty long

- term averages are shown along with 2009 aver ages in Figure 9

- 5 below

.

Figure 9

- 5

. Hourly 2009 PM 2.5 TEOM Averages at Liberty Compared to Long

- Term 2000

- 2008 Averages

Liberty TEOM data show the same diurnal trend in 2009 as in previous years but at lower concentrations. Additionally, the dotted high

- low lines visually indicate a higher nighttime difference between long

- term and 2009 data. This is evidence that t he 2009 low

- production conditions led to lower concentrations during typical peak per iods, supporting the control strategy addressed in this SIP

.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 73

The Lawrenceville long

- term averages are shown along with 2009 averages in Figure 9

- 6 below.

Figure 9

- 6

. Hourly 2009 PM 2.5 TEOM Averages at Lawrenceville Compared to Long

- Term

2000

- 2008 Averages

Lawrenceville TEOM data show an overall decrease in concentrations in 2009, with the high

- low lines showing a slightly higher difference between long

- term and 2009 daytime concentrat ions.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 74

Decreases in overall concentrations at both sites can be due to regionally lower production levels, while lower nighttime levels at Liberty may be evident of lower local source production levels. To examine this, differences in concentrations betw een the two sites were calculated.

Table 9

- 2 below shows quarterly average FRM data over a 5

- year timeframe for years 2005

- 2008 and for 2009. Averages are given for Liberty, Lawrenceville, and the difference between the two sites (Liberty minus Lawrencev ille).

Table 9

- 2

. PM 2.5 FRM Quarterly Averages, 2005

- 2008 and 2009

Liberty 1Q 2Q 3Q 4Q

2005

- 2008 Average 14.9 19.1 23.6 18.9

2009 15.0 13.7 15.1 16.4

Lawrenceville 1Q 2Q 3Q 4Q

2005

- 2008 Average 12.5 13.8 19.4 12.3

2009 12.7 11.2 12.9 9.7

Difference (Lib.

- Law.) 1Q 2Q 3Q 4Q

2005

- 2008 Average 2.4 5.2 4.2 6.6

2009 2.3 2.5 2.2 6.7

The difference parameters for 2 nd and 3 rd quarters in 2009 are significantly smaller than in previous years, coinciding with low production levels at local sources.

At the U. S. Steel Mon Valley Works

– Clairton Plant, Batteries 13

- 15 were idled from Mar.

- Dec. 2009, along with B Battery from Apr

. - Jun. 2009, due to economic recession. Batteries 7

- 9 were also permanently idled in April 2009. At the NRG Elrama power plant, all boiler units operated at an average capacity of 8.1% from March to October 2009.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 75

To further illustrate the lower localiz ed source influence in 2009 data, a plot of the Liberty

Lawrenceville TEOM difference is shown in Figure 9

- 7 for 2009 and previous years. For this chart, long

- term hourly averages for 2000

- 2008 are compared to hourly averages for 2009. The

hours have been shifted by 12 hours to show the nighttime period in the center of the chart.

Figure 9

- 7

. Hourly 2009 PM 2.5 TEOM Average Differences Between Liberty and Lawrenceville Compared to Long

- Term 2000

- 2008 Data

The nighttime peak in the Liberty

- Lawrenceville difference has been lowered in the 2009 data, reflecting the influence of reduced production in 2009 compared to that of normal production in

2000

- 2008. Decreases in concentration differences are greatest in the late evening/early morning period.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 76



## 10 Emergency Episodes

Subpart H of 40 CFR part 51 specifies requirements for SIPs to address emergency air pollution episodes in order to prevent air pollutant levels from reaching levels determined to cause significant harm to the health of persons. No levels are currently recommended by EPA for PM 2.5 emergency episodes, however ACHD Rules and Regulations Article XXI §2 106.03, which defines the procedures for emergency air pollution episodes as well as the values for air pollutants, includes PM 10 levels. ACHD will use the levels set for PM 10 as PM 2.5 levels.

ACHD assumes one μ g/m 3 of PM 2.5 to be equal to at least one μ g/m 3 of PM 10 , therefore if any

PM 2.5 monitor exceeds any of the levels listed for PM 10 , it will be assumed that the PM 10 levels have been exceeded, and appropriate action will be taken according to the predetermined Episode Actions of Article XXI §2106.04.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 77



## 11 Legal Documents

11.1 Notice of Public Hearing and Comment PeriodLiberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 78



### 11.2 Transmittals of Hearing Notice to PA DEP and EPALiberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 79Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 80



### 11.3 Proof of Publication and Certification of Public HearingLiberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 81Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 8 2



### 11.4 Summary of Public Comments and Responses

Comment and Response Document for the Proposed SIP Revision 75 Revision to State Implementation Plan for PM 2.5 for Allegheny County Liberty

- Clairton PM 2.5 Attainment Plan, 2006 NAAQS

February 19, 2013 Public Hearing Public Comment Period ending March 5, 2013

GENERAL

Comments related to the PM 2.5 SIP in general.

1. Comment: Coal coke smell is evident throughout Liberty Borough. Liberty and surrounding communities deserve the strongest level of protection possible.

Commenter : Reverend Don Polito, Pastor, Liber ty Presbyterian Church.

Response : ACHD appreciates the comment and will continue to work on air quality plans in order to protect the community.

2. Comment: Evidence suggests that daily peaks of pollution in the Mon Valley are triggering asthma attacks, other lung diseases, and heart attacks. If residents are asked to reduce emissions on bad air quality days, industry should be asked to curtail emissions on those days as well.

Commenter : Clean Water Action.

Response : A SIP is a plan developed to meet attainment of NAAQS to protect public health. On Air Quality Action Days, both the public and industry are requested to minimize emissions. ACHD will continue to work on air quality plans in order to protect the community.

3. Comment: The SIP shows futu re design values that are close to the NAAQS. ACHD should closely monitor emissions and take aggressive action should attainment not be met. U. S. Steel should be applauded for their actions to date but also asked to continue the installation of newer

te chnologies such as low

- emission quench towers.

Commenter : Clean Water Action.

Response : ACHD will continue to monitor the air in Allegheny County and work with industry and other pollutant sectors in order to control emissions.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 83

4. Comment: Although the SIP shows a decrease in particulate matter, the SIP does not address the exposure to volatile carcinogenic gases from the coke plant. Daily exposures to these emissions should be made publically available, especially for peak periods.

Commenter : Constance Jennings, MD.

Response : This plan is only for the control of fine particulates. However, up

- to

- date

information on monitored data is available at the ACHD web site: http://www.achd.ne t/air/index.php

.

5. Comment: The Mon Valley has a high rate of heart attacks and cancer due to airborne particulates. Laws for the control of particulates from vehicles and off

- road equipment are not being enforced. Also, ACHD should develop a prevention and testing program for toxics such as mercury and arsenic, similar to lead testing for children.

Commenter : William Donofrio, Your Environment.

Response : ACHD appreciates the recommendation and will continue to work on air quality plans and preventio n programs in order to protect the community. The comment related to enforcement of particulate matter from vehicles and off

- road equipment may relate to the City of Pittsburgh’s “Clean Air Act of 2010,” which is not applicable to the Mon Valley.

6. Commen t: Clean air should be a priority for SWPA, plans for air quality should be continued, and current regulations should not be weakened.

Commenter : Joan Smith; and Christopher D. Conte.

Response : ACHD follows all national air quality rules and regulat ions and will continue to implement local regulations and programs for better air quality. No regulation has been weakened in this plan.

7. Comment: On Jan. 4, 2013, the U.S. Court of Appeals for the District of Columbia Circuit (D.C. Circuit) remanded to EPA the Final Clean Air Fine Particle Implementation Rule. The D.C. Circuit found that EPA erred in the implementation of the 1997 PM 2.5 NAAQS acc ording to Subpart 1 of Part D of Title I of the Clean Air Act, rather than Subpart 4. EPA is still interpreting this court decision and its potential implications for attainment demonstrations.

Commenter : U.S. EPA Region III.

Response : ACHD acknowledg es the court ruling and will work with EPA in response to potential implications to the attainment demonstration. ACHD believes the requirements of both Subpart 1 and Subpart 4 have been satisfied (see responses to comments 8 and 27).Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 84

8. Comment: Based o n the Jan. 4, 2013 D.C. Circuit ruling, the Liberty

- Clairton SIP should comply with Title I, Part D, Subpart 4 of the Clean Air Act. The SIP must be revised to reflect the requirements applicable to moderate areas under Subpart 4. This includes a due dat e of June 14, 2011, an attainment deadline of Dec. 31, 2015 without contingency measures, compliance with RACM by Dec. 14, 2013, and presumptive regulation of VOCs and NH 3

.

Commenter : Clean Air Council, PennFuture, GASP, Clean Water Action, Sustainable

P ittsburgh, Sierra Club, REACH Mon Valley, and Center for Coalfield Justice.

Response : With addition of discussion of VOCs and NH 3 , ACHD believes the requirements of both Subpart 1 and Subpart 4 have been satisfied. (See also response to previous comment and comment 27.)

9. Comment: The Liberty

- Clairton area is at high risk of being reclassified as a “serious” nonattainment area under Title I, Part D, Subpart 4 of the Clean Air Act if attainment is not met. The attainment demonstration shows no practical support for its conclusion that will attain the 24

- hour standard by Dec. 14, 2014. The lack of federally enforceable commitments and reductions beyond 2011 will likely lead to nonattainment and reclassification to “serious” by EPA.

Commenter : Clean Air Council et al.

Response : ACHD is confident that attainment will be reached with this SIP.

10. Comment: The executive summary should include the revised PM 2.5 NAAQS, especially since the projected design values are near or below the new 12 μg/m3 annual st andard.

Commenter : U. S. Steel Corporation.

Response : This SIP is specific to the 2006 NAAQS and provides an attainment demonstration to those standards only. The 2012 NAAQS will be addressed in future

demonstrations.

PROBLEM STATEMENT

Comments related to the description of the Liberty

- Clairton PM 2.5 problem.

11. Comment: Lawrenceville data is used in the analysis of regional PM 2.5 concentrations. Lawrenceville does not represent background conditions for Allegheny County or the Liberty

Clairton A rea. Averaging Lawrenceville speciation data with Florence and Greensburg data may be skewing the calculated excess at Liberty. Additionally, Liberty data should not be considered uncommon to SWPA since its species composition is similar to other sites.

Commenter : U. S. Steel Corporation.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 85

Response : The Speciation Report in Appendix C

- 1 helps explain the regional and local analysis. The purpose of the analysis is to separate Liberty

- dominant species from the more widespread species. Lawrenceville is typically representative of urban excess emissions but is also part of the regional component. Averaging Lawrenceville with Florence and Greensburg for the regional component minimizes site influences at each monitor, and the average of the 3 sites is the best representation of SWPA air surrounding the Liberty

- Clairton

area.

For the calculations used in the attainment tests, speciation data is combined with FRM data using the SANDWICH technique, which adjusts the species compositions. Figures 4

- 1 and

4

- 5 in Appendix C

- 1 show that the SANDWICH technique produces nearly identical species concentrations for the Lawrenceville, Florence, and Greensburg sites on both long

- term and high

- day bases.

Although the species are the same, the Liberty data is considere d to be uncommon to SWPA because it shows species concentrations that are specific to a smaller area. It is not a highest

concentration monitor that is consistent with air throughout the SWPA air shed; rather, it represents a portion of long

- range transpo rt and urban PM 2.5 along with a localized component. This concept is part of the basis for designating Liberty

- Clairton as a separate area within Allegheny County.

12. Comment: Figures 2

- 3 and 2

- 4 should indicate if there are any monitors that collected in sufficient data to calculate a valid design value, in accordance with 40 CFR Part 50 Appendix N.

Commenter : U.S. EPA Region III.

Response : Figures 2

- 3 and 2

- 4 have been noted accordingly. Appendix B has been revised to include details of the incomplet e data and attainment status of each monitor, as taken from the EPA design values web site ( http://www.epa.gov/airtrends/values.html ). The Liberty monitor satisfied all data requirements.

METEOROLOGY Comments related to the meteorological analysis included in the SIP.

13. Comment: Figure 2

- 2 should note that hourly Tapered

- Element Oscillating Microbalance (TEOM) monitor data and not Federal Reference Method (FRM) monitor data were used for th e data shown in the figure.

Commenter : U.S. EPA Region III.

Response : Figure 2

- 2 has been noted accordingly.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 86

14. Comment: Section 2.3 mentions that meteorological data from Pittsburgh airport data is assumed representative of stability conditions through out the county; but, the report referenced later in the section states that valley meteorology complicates the connection between emissions controls and air quality benefits.

Commenter : U. S. Steel Corporation.

Response : ACHD used the best available me teorological information deemed representative for the modeling demonstration. The closest, twice daily, National Weather Service (NWS) upper air data is collected near the Pittsburgh International Airport in Moon Township, PA,

about 24 miles northwest of the U. S. Steel Clairton Plant. (Note that the NWS operates only about 70 upper air stations throughout the conterminous U.S.) For modeling purposes, this data is representative of the stability across Allegheny County. The meteorological evaluation gi ven in Appendix A

- 1 took valley conditions into consideration by examining morning ground inversions beginning at 1 o C in strength and assuming that valley areas on days when such PIT NWS inversions were present would also be experiencing significant

invers ions.

15. Comment: The SIP states that precipitation helps end a pollutant event. This should be revised to reflect that precipitation can help end an inversion, regardless of PM 2.5 levels.

Commenter : U. S. Steel Corporation.

Response : Precipitation he lps to end a pollutant event, regardless of whether an inversion is present or not. So, the statements in the SIP related to the effects of precipitation are appropriate.

16. Comment: ACHD historically and erroneously points to meteorology as a cause of nonattainment. While inversions may inhibit dispersion, nonattainment levels of PM 2.5 are caused by emissions. If there were no emissions present, there would be no peak levels. Meteorology cannot be controlled; the direct relationship between source emissions and impacts must be the

focus of SIP efforts.

Commenter : Clean Air Council e t al.

Response : Inversions can lead to increased levels of pollutants anywhere in Allegheny County. In the case of the Liberty

- Clairton area, nonattainment can be attributed to a combination of emissions, complex terrain, and meteorology acting together to trap pollutants in the area.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 87

CONTROL STRATEGY Comments related to the controls used to show projected attainment.

17. Comment: The attainment plan includes emissions reductions of SO 2 and NO

x from the Cross State Air Pollution Rule (CSAPR) as a contr ol measure. On August 21, 2012, The D.C. Circuit issued a decision to vacate CSAPR and to continue administering the Clean Air Interstate Rule (CAIR) for controls, pending the promulgation of a valid replacement. EPA is evaluating the

ramifications of th at decision and its potential implications for attainment plans. At this time, it is reasonable for the Liberty

- Clairton attainment plan to rely on CAIR for the control of interstate

emissions.

Commenter : U.S. EPA Region III; Clean Air Council et al.

R esponse : ACHD will rely on CAIR, state, and permit controls until a replacement for CSAPR is promulgated. However, at this time, ACHD believes that the inventory used in the federal CAIR modeling demonstration is an outdated inventory that may not adequa tely represent future emissions from the electric generating unit (EGU) sector; the CSAPR future case inventory was therefore used in the modeling demonstration. ACHD maintains that, in lieu of any additional inventory, the CSAPR inventory is an updated v ersion of the CAIR inventory that is best representative of expected EGU controls. See Section 3.1, Section 5.3.5, and Appendix E

- 6 of the SIP for more details on the CAIR/CSAPR inventories.

18. Comment: ACHD cannot rely on expected emissions reductions from CSAPR that are not SIP

approved. Even if CSAPR was not vacated, ACHD would still be obligated to delineate the specific controls and limitations from each source.

Commenter : Clean Air Council et al.

Response : See response to previous comment.

19. Comment: Control measures contained in the consent order with U. S. Steel should be clearly identified in the SIP. The consent order should be attached to the plan as supporting information.

Commenter : U.S. EPA Region III.

Respons e : Control measures are listed in Section 3.2 of the SIP and, as stated, are included in a consent agreement that, in turn, is federally enforceable through the installation permit and Title V permit. The consent order agreement as of 2011 is provided as supplemental information in Appendix F

- 2.

20. Comment: ACHD must list each specific emissions reduction measure at the U. S. Steel Coke Plant and ensure that those provisions are federally enforceable.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 88

Commenter : Clean Air Council et al.

Response : See response to previous comment.

21. Comment: The consent order amendment date of July 2011 should be added to the SIP. Additionally, the consent order identifies that the consent order was entered into in response to visible emissions and opacity violations; U. S. Steel disagrees with this statement.

Commenter : U. S. Steel Corporation.

Response : The consent order amendment date of July 2011 has been added to the SIP. Regarding the reason for the consent order, this order resolves several violations at t he Mon Valley

Works. Section 3.2 of the SIP has been revised for clarification.

22. Comment: The regional inventory controls must be federally enforceable. These controls are not

listed in the SIP.

Commenter : Clean Air Council et al.

Response : The compliance modeling includes an expected actual emissions inventory, based on both federally enforceable local and regional controls, and, in the case of more distant sources, expected future activity. Appendix E

- 2 specifies in detail the controls used in the regional inventories. Section 3.4 of the SIP has been revised for further clarification.

23. Comment: Emissions reductions included shutdowns from local sources adjacent to the Liberty

Clairton area, including GM, Ryan Metals, and Precoat. The se shutdowns must be permanent, enforceable and quantifiable. The SIP should include information to support the permanent shutdowns of these facilities, as well as quantification of the emissions reductions.

Commenter : U.S. EPA Region III; Clean Air Council et al.

Response : These facilities have been permanently shut down, without emissions credits or current operating permits. Any future operation at these locations would require a new permit and new source review. Additional language has been ad ded to Section 3.3 of the SIP for clarification. Also, quantifiable emissions for Allegheny and Washington County facilities, base and future cases, have been added to Appendix F

- 2.

24. Comment: The SIP identifies the U. S. Steel Clairton Plant as the larg est pollutant source. The SIP should be revised to state that the Clairton Plant is the largest known individual source in the Liberty

- Clairton area, as the largest sources of pollutants are background and regional sources.

Commenter : U. S. Steel Corpor ation.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 89

Response : The SIP has been revised accordingly.

25. Comment: The Battery 19 discussion should be updated to state that 25 heating walls were replaced by 2012, and if necessary, an advanced heating plan will be implemented to reduce

emissions.

Comm enter : U. S. Steel Corporation.

Response : The SIP has been revised accordingly.

26. Comment: Based on emissions inventory, U. S. Steel’s Clairton Plant is the primary influence on ambient air in the Liberty

- Clairton area. Controls must be in place in a timely fashion, as there are no further reductions planned beyond 2013.

Commenter : Clean Ai r Council et al.

Response : The attainment demonstration is based on controls from both the local and regional sources of PM 2.5 . The primary influence on the ambient air in SWPA is regional (incoming) air pollution. The largest controls locally in Liber ty

- Clairton are for the Clairton Plant. The projected year of attainment is 2014, so reductions beyond that have not been

considered for this SIP.

EMISSIONS INVENTORY Comments related to the pollutant inventories used for the baseline and projected

emis sions.

27. Comment: Emissions inventories for the base and projected years show decreases of PM 2.5 and its precursors. Address or elaborate on why control measures were needed for PM 2.5 , SO 2 , and NO

x and not for VOC and NH 3

.

Commenter : U.S. EPA Region III.

Response : Direct PM 2.5 represents the largest amount of localized excess at Liberty monitor, while regional sulfates and nitrates are the largest portions of the regional component of

PM 2.5 in SWPA. Controls for these pollutants lead to the largest reductions in SWPA and the Liberty

- Clairton area. While not the focus of the control strategies, Tables 4

- 1 and 4

- 2 also

show reductions for VOC and NH 3 for the Liberty

- Clairton area.

Additionally, VOC emissions showed negligible transformation to secon dary organic aerosols (SOA) in the CAMx model, both regionally and locally. NH 3 emissions also

showed little transformation to NH 4 not associated with sulfates and nitrates (see Section 5.4Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 90

of the SIP). Therefore, additional control of these precursors i s unlikely to show reductions in the modeled impacts.

28. Comment: The PM 2.5 emissions provided in Table 5

- 1 for the Mitchell and Elrama power plants do not match those reported in PA DEP’s eFACTS system. Elaborate on this discrepancy.

Commenter : U.S. EPA Region III.

Response : Some reported PM 2.5 2007 facility emissions in the eFACTS system do not include or are erroneous for the condensable portion of PM 2.5 . Condensable PM 2.5 emissions

were included in the 2007 MANE

- VU inventory used in the modeling , as calculated according to the TSD in Appendix E

- 1, similar to other inventories such as the National Emissions Inventory (NEI).

29. Comment: More recent emissions data should be used for power plants on “long term cold storage” for future modeled project ions.

Commenter : Clean Air Council et al.

Response : Unless permanently retired with PJM Interconnection, power plants proposed for deactivation were kept in the future case inventory. The future case modeling simulation may therefore be considered con servative for power plant impacts. Discussion of the proposed deactivations in 2012 was included as weight of evidence.

MODELING Comments related to the methodology used for modeling and the resulting modeled impacts.

30. Comment: The explanation of the selection of the nearby receptors used in the modeling is unclear. It is also unclear if the receptor selection is similar to the process described in Section 3.2 of the EPA Modeling Guidance.

Commenter : U.S. EPA Region III.

Re sponse : The selection of the nearby receptors for Liberty and Clairton is described in more detail in the Modeling Protocol (Appendix G

- 1). The selection of the receptors varies somewhat from the method described in Section 3.2 of the EPA Modeling Guidan ce, as the Liberty

- Clairton attainment tests were more of a local area analysis than a grid cell analysis. The selection of receptors for the FRM locations were based on the extent of concentrations contours seen in previous modeling efforts.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 91

31. Comment: Additional language would be helpful in Section 5 to explain the construction of the local and regional modeled impacts shown in Tables 5

- 7 through 5

- 10

.

Commenter : U.S. EPA Region III.

Response : The local and regional impacts were tracked separately by the CAMx model using the Particulate Source Apportionment Technology tool. The modeled impacts from point sources identified for local treatment are summed as the local portion of the CAMx impacts. Additional language has been added Section 5 to furth er explain the treatment of the local and regional impacts.

32. Comment: It is unclear if the Relative Response Factors (RRFs) used for the unmonitored area analysis were calculated from a single grid cell or from a combination of grid cells around the

Libe rty and Clairton monitors.

Commenter : U.S. EPA Region III.

Response : The unmonitored area analysis is described in more detail in Appendix G

- 3. The unmonitored analysis was performed using the EPA Modeled Attainment Test Software (MATS) using the defa ult options. The RRFs were based on modeled results for each single grid cell, with the design values spatially interpolated based on the modeled gradients.

33. Comment: Meteorological conditions in 2007 are not representative of maximum PM 2.5 concentratio ns. The maximum concentrations given in Table 2 of Appendix A are higher in 2005, 2006, and 2009 than the maximum concentration in 2007.

Commenter : Clean Air Council et al.

Response : The baseline year 2007 was chosen because it was a recent year in wh ich a complete and verified national emissions data set was available from Regional Planning Organizations (RPOs) and represented typical meteorology, developed specifically for PM 2.5 and ozone demonstrations. The inventories were reviewed for SIP

- quality and were considered the best available at the time of the modeling for this SIP.

Monitored data shows that 2007 is typical of high PM 2.5 days for the 5

- year weighted

timeframe of 20 05

- 2009. The attainment tests outlined in EPA Modeling Guidance are based

on a 5

- year weighted methodology, and the baseline year is used to represent a 5

- year timeframe. Year 2007 contains the second highest amount of days with concentrations greater th an or equal to 35.5 μg/m3 (the level at which an exceedance of the new standard may be registered) and the most consecutive days greater than or equal to 35.5 μg/m3.

Additionally, the 24

- hour attainment test is based on averages of the 98 th

- percentile v alues,

not maximum values. The 98 th

- percentile concentration for 2007 was 54.7 μg/m3, which is close to a midpoint between 2005 and 2009 (98 th

- percentile values of 69.6 μg/m3and 45.3Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 92

μg/m3, respectively). Thus, year 2007 is an appropriately representativ e year over the 5

- year timeframe for PM 2.5 concentrations.

34. Comment: ACHD has partially double

- counted emissions reductions from controls and shutdowns occurring in 2009.

Commenter : Clean Air Council et al.

Response : The attainment demonstration uses a baseline modeled year of 2007 applied to a weighted timeframe of 2005

- 2009 according to the methodology outlined in the EPA Modeling Guidance. There is inherently some under

- and over

- counting in the combination of modeled impacts (based on 1 year of e missions) with monitored impacts (based on 5 years of monitored data), and the local source shutdowns occurred for only a portion of 2009. Since the modeled/monitored results are combined in a relative sense (see also responses to comments 35 and 37), the se discrepancies would not adversely impact the modeling

demonstration.

35. Comment: The WRF meteorological model failed the performance benchmarks by overestimating winds. Overestimation of winds can lead to underestimation of PM 2.5 impacts.

Commenter : Clean Air Council et al.

Response : The WRF model is a state

- of

- the

- science meteorological model appropriate for air quality modeling use. The benchmarks presented on the soccer plots in Appendix G

- 2 are not intended to be used as an absolute pass/fail f or model performance. They are intended to be a general guide for interpreting such performance. These guidelines were developed from examining historical meteorological applications which were used for photochemical air quality studies. The majority of the model applications used 4 km horizontal grid spacing and fairly short time periods during which high ozone occurred in stagnant conditions.

It is also important to understand that the reported statistics are monthly average values and that at any hou r the model may be over or underestimating the wind speeds. Furthermore, no model is able to capture the subtle features of the atmosphere. State

- of

- science meteorological modeling was conducted for the Liberty

- Clairton PM 2.5 SIP, and the

evaluation of t hat state

- of

- science modeling was suggestive of where caution should be taken in interpreting the air quality modeling results.

Additionally, the modeling results are being used in a “relative” way. EPA recognizes limitations in modeling; thus, procedure s developed by EPA to reduce limitations include the

use of Relative Response Factors (RRFs) for attainment tests . So, in conformance with EPA’s recommended model attainment test, model results for the projected year (2014) were compared to results for th e baseline year (2007). Therefore, model performance is acceptable for estimating future attainment.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 93

36. Comment: The selection of the CAMx model over CMAQ is not justified. It should be noted that CMAQ is the EPA

- developed model. It was used for PA SI Ps for the 1997 NAAQS, including Liberty

- Clairton, Pittsburgh

- Beaver Valley, and Philadelphia

- Wilmington. In non

- attainment areas where both models have been used (e.g., Los Angeles and the South Coast Air Basin), CMAQ is the principal model while CAMx ha s been restricted to a supporting role, providing corroborating evidence to the CMAQ model predictions.

Commenter : Clean Air Council et al.

Response : There is no specific EPA

- preferred model for photochemical modeling. CAMx

was selected as the model f or reasons specified in the Modeling Protocol (Appendix G

- 1), including local source treatment and two

- way grid nesting features that are not available in the current version of CMAQ. CAMx has been used as the principal model for recent EPA modeling simul ations such as CSAPR and for SIPs such as the South Coast Air Basin/Los Angeles 2007 Air Quality Management Plan.

37. Comment: The CAMx model is inaccurate due to severe underestimation of PM 2.5 species and understates emissions controls. The tendency of u nderestimation invalidates the CAMx predictions and the attainment demonstration. Also, due to the underestimation of CAMx, CMAQ should be used as corroborative evidence or supplemental runs for the SIP.

Commenter : Clean Air Council et al.

Response : Both the CMAQ and CAMx models are sufficiently accurate for this type of demonstration. EPA recognizes limitations in the models; the purpose of procedures developed by EPA to use Relative Response Factors (RRFs) for the attainment tests is to

minimize these limitations. (See also response to comment 35.)

Furthermore, as noted in EPA’s 2007 Modeling Guidance, “[b]y definition, models are simplistic approximations of complex phenomena” (EPA, 2007, pg. 98). This is especially

true for PM where differen t measurement technologies can produce large differences in concentrations (e.g., different carbon measurement technologies can vary by 30%). For the Liberty

- Clairton CAMx application, the model is achieving the PM Performance Criteria for all species but nitrate (as noted in the Table 7

- 8 of Appendix G

- 2). The CAMx nitrate underprediction occurs in the summer and warm months when observed and modeled nitrate

concentrations are near zero because nitrate is a volatile chemical whose formation is favored

un der cooler temperatures. During the winter when nitrate concentrations are higher, CAMx performs much better and achieves the PM Performance Criteria (see Figure 7

- 19 in Appendix G

- 2). As noted in Figure 2

- 3 of Appendix G

- 2, ammonium nitrate is a small

c omponent of annual PM 2.5 at Liberty (8%) and primarily occurs in the winter when CAMx

achieves the PM Performance Criteria.

For projecting 2014 PM 2.5 concentrations using the CAMx 2007 and 2014 modeling results, EPA’s Modeling Guidance was followed using the Speciated Modeled Attainment TestLiberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 94

(SMAT), which utilizes the modeling results in a relative sense to scale the observed current year PM 2.5 species concentrations to project 2014 future year PM 2.5 concentrations. EPA recommends using the relative chang es in the modeling results between 2007 and 2014 because it roots the PM projections in the observations and reduces uncertainties; for example, if the model is underestimating the 2007 PM 2.5 species, it is also likely underestimating the 2014 PM 2.5 specie s concentrations. So, by taking their ratio to scale the

observed PM 2.5 species concentration, the underestimation cancels out in the 2014 projection procedure. Thus, a CAMx underestimation or overestimation bias does not mean that it

underestimates or o verestimates the effects of the changes in emissions between 2007 and 2014 on PM concentrations since the modeling results are used in a relative fashion as recommended by EPA.

38. Comment: Nearby receptors for primary PM 2.5 modeling are too coarse to captu re maximum concentrations from local sources. To capture maximum concentrations, receptors should be spaced at 25 m or less, without averaging the receptors.

Commenter : Clean Air Council et al.

Response : The nearby receptors were chosen to represent t he FRM sites within a perimeter of similar terrain, and there are no sources that were not accounted for within the 100 m spacing. This receptor methodology uses a much finer scale than that prescribed by the EPA Modeling Guidance, which recommends averag ing the concentrations across a 7 x 7 array of grid cells centered on the monitor.

39. Comment: The CAMx model is invalid for predicting primary PM 2.5 concentrations from large point sources within a fine grid at 0.8 km spacing. The submodel PiG in CAMx ha s not been approved by EPA; AERMOD should have been used for the modeling of local primary PM 2.5

. Additionally, Liberty meteorology was not used for the AERMOD comparison given in Appendix

G

- 3.

Commenter : Clean Air Council et al.

Response : The choice of CAMx was reviewed with EPA Region III during the development of the Modeling Protocol. CAMx was one of several models recommended by the EPA to predict fine particulate matter concentrations in nonattainment areas. Section 13.1 in EPA’s 2007 Modeling Guidance document notes that “a State may use a regional photochemical grid model to address both primary and secondary components of particulate matter ....”

The plume

- in

- grid modeling option incorporates a puff/plume model within a larger

- scale grid mod el such as CAMx, to account for significant individual emission sources in an area of interest. According to Karamchandani, P., Vijayaraghavan, K., and Yarwood, G. (2011)

in an article titled “Sub

- grid scale plume modeling” in the journal Atmosphere (vol. 2 , pages 389

- 406), “[t]he embedded model tracks the sub

- grid scale process (e.g., elevated point source emissions) until the fine scale variability becomes unimportant (referred to as theLiberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 95

‘puff dumping’ or ‘hand

- over’ point), at which point the grid model takes over the calculations for that process while the embedded model continues tracking sub

- grid scale processes” (pg. 394). Karamchandani, et al., 2011, go on to say that a plume “is represented by a myriad of three

- dimensional puffs that are advected and dispersed according to the local micrometeorological characteristics.... Also, the effects of buoyancy on plume rise and initial dispersion are simulated by solving the conservation equations for mass, heat, and momentum.” Furthermore, “[c]hemical spec ies concentrations in the puffs are treated as perturbations from the background concentrations” (pg. 395).

Lastly, the comparison to AERMOD in Appendix G

- 3 used Liberty meteorological data for the AERMOD simulation, with PIT airport data used only for su bstitution during missing periods. CAMx with PiG estimated concentrations as well as or better than CAMx with

AERMOD.

40. Comment: The CAMx model is invalid for predicting secondary PM 2.5 concentrations from large point sources within a fine grid at 0.8 km spacing. The CAMx model uses eddy diffusion coefficients for treating turbulent diffusion in the atmosphere. This K

- theory approximation is known to be invalid near large point sources

.

Commenter : Clean Air Council et al.

Response : The use of the K

- theory approximation was appropriate for this modeling situation. The

commenter’s K

- theory statement is likely based on pages 885 through 889 in Seinfeld, J.H., and Pandis, S.N. (1998), Atmospheric Chemistry and Physics: From Air Pollution to Climate Change (New York: John Wiley & Sons). In particular, page 889 states that a key equation that describes statistical properties of concentrations “is a valid description of turbulent diffusio n and chemical reaction as long as [specified basic restrictions] hold, namely, that the reaction processes are slow compared with turbulent transport and the characteristic lengthscale and timescale for changes in the mean concentration field are large co mpared with the corresponding scales for turbulent transport. Because the eddy timescale...and the lengthscale...are often quite large in the atmosphere, the above conditions are violated near strong isolated sources.”

However, the discussion on page 889 con tinues with “...to satisfy the condition that the characteristic lengthscale of the concentration field be much greater than that of the turbulence, the spatial scale for variations in [concentration]... must be of the order of 100 to 1000 m. In addition, und er these

conditions the timescale of the fastest reactions must be no smaller than on the order of about 10 min. The conclusion we draw at this point is that [the key equation] is a valid model provided it is applied

to situations in which chemical reacti ons are ‘slow’ and the distribution of sources is ‘smooth’ ” (emphasis in original). The source

- receptor situation in the nonattainment area and the way the situation was modeled satisfy these two criteria.

41. Comment: The SIP states on Page 21 (also in th e Modeling Protocol, Appendix G

- 1) that CB6 chemical mechanism represents the latest understating of photochemistry. This must be a typographical error, which should read “understanding” of photochemistry.

Commenter : Clean Air Council et al.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 96

Response : The SIP and Appendix G

- 1 have been corrected accordingly.

42. Comment: CAMx predictions may be misleading since its 25 vertical layers are collapsed from the 37 WRF layers. The CMAQ Operational Guidance Document states that layer collapsing is

“not recomm ended, as dynamical inconsistencies can develop and lead to misleading results.”

Commenter : Clean Air Council et al.

Response : Most CAMx applications use layer collapsing to reduce the number of vertical layers in CAMx for computational efficiency. Fo r the Liberty

- Clairton SIP modeling, a no layer collapsing sensitivity test was performed and found essentially identical modeling results whether layer collapsing was used or not (see Appendix G

- 3). Note that the Denver ozone SIP also used a similar laye r collapsing scheme to reduce the 37 vertical layers in WRF to 25 in CAMx and also conducted a no layer collapsing sensitivity test and found essentially identical results. Thus, there do not appear to be any inconsistencies whether layer collapsing is us ed or not. EPA’s recommendations for running CMAQ are not relevant

to CAMx.

43. Comment: CAMx uses boundary conditions derived from the predictions of the global MOZART model without justification. In the CSAPR modeling, EPA used boundary conditions derived from

the GEOS

- Chem model. The selection of MOZART over GEOS

- Chem should be document ed.

Commenter : Clean Air Council et al.

Response : At the time that the CAMx model inputs were developed, 2007 global chemistry model output was readily available for only the MOZART global chemistry model. Furthermore, MOZART model produces comparable results to other global chemical transport models. MOZART provides sufficient horizontal resolution to simulate chemical transport on synoptic weather scales and sufficient vertical resolution to simulate mass exchange between the upper

- and surface

- laye r atmospheres.

44. Comment: CAMx sensitivity to key modeling inputs such as initial conditions, boundary conditions, and emissions has not been analyzed.

Commenter : Clean Air Council et al.

Response : The sensitivity of the model to local emissions sources was extensively analyzed using the Plume

- in

- Grid module and PM Source Apportionment Technology (PSAT) probing

tool. The modeled local source contribution to annual PM 2.5 concentrations at Liberty was compared to an estimate based on analysis of ob servations. Overall model performance was evaluated and found satisfactory.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 97

45. Comment: The ACHD staff is to be commended for conducting some of the most sophisticated localized modeling ever performed. The modeling projects that the area will be

in atta inment with both the 2006 daily and 2012 annual PM 2.5 standards.

Commenter : Greater Pittsburgh Chamber of Commerce

.

Response : ACHD staff appreciates the comment.

ATTAINMENT TESTS Comments related to the assumptions and methodology used for the design value

calculations.

46. Comment: ACHD should consider the use of significant figures in the calculations shown in

Sections 6.4 and 6.5.

Commenter : U.S. EPA Region III.

Response : The data shown for the attainment test calculations were rounded to a prec ision of three decimal places for all intermediate calculations. For better comparison to the NAAQS, the final design values will be revised in the tables to show the values according to rounding conventions given in 40 CFR Part 50 Appendix N, with the an nual design values

rounded to the nearest tenth and the 24

- hour rounded to the nearest whole number.

47. Comment: Liberty speciation data was used to represent both Liberty and Clairton in the attainment tests. This assumption is not accurately or adequate ly supported by the information given in the SIP.

Commenter : U. S. Steel Corporation.

Response : With no other speciation data available, the Liberty speciation data is used to represent species composition throughout the area. This follows the EPA Mod eling Guidance methodology to use the nearest speciation site when no other data is available. The SANDWICH technique used for the attainment tests adjusts the species fractions to the FRM

data measured at the Clairton site.

48. Comment: Tables 6

- 5 throug h 6

- 8 show projected data for the weighted timeframe of 2005

- 2009,

which does not coincide with the monitored data.

Commenter : Clean Air Council et al.

Response : ACHD apologizes for the confusion in these tables. The years shown are based

on the recal culation of the 2005

- 2009 24

- hour design values using the modeled reductions,Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 98

according to the EPA attainment test methodology. The tables have been revised to show “Year 1, Year 2,” and so on.

RACT/RACM Comments related to the RACT/RACM analysis in the SIP.

49. Comment: The SIP states that the Clairton Plant coke batteries have some of the nation’s strictest standards. As part of the RACT/RACM analysis, a more specific explanation should be provided of which standards apply to these units in order for EP A to determine if they meet RACT/RACM requirements.

Commenter : U.S. EPA Region III.

Response : A detailed list of controls by process for the U. S. Steel Clairton Plant has been provided in Appendix I. The RACT/RACM section of the SIP has been revised for

clarification.

CONTINGENCY MEASURES Comments related to the additional contingency controls used in case the plan fails to demonstrate attainment by the attainment date.

50. Comment: It is inappropriate that U. S. Steel’s Clairton Plant is the only sou rce required to reduce emissions should attainment not be met. Such an approach is inequitable and unreasonable considering that significant sources of PM 2.5 and precursors upwind of the Liberty

- Clairton area would not be obligated to reduce emissions. I f CSAPR is not enforceable due to the vacatur, U. S. Steel may be forced to implement contingency measures based on poor background or regional air quality. The language in Section 8 should be revised to allow for the cause of nonattainment to be

evaluate d prior to the contingency measures taking effect.

Commenter : U. S. Steel Corporation.

Response : ACHD recognizes that both local and regional sources impact the Liberty

Clairton area and will continue to analyze air quality contributions in the future. For the purposes of this SIP, the contingency measures are appropriate considering the control strategy and supporting analyses. Continuous monitored data shows that exceedances of the

24

- hour PM 2.5 standard are driven by short

- term peak levels occurrin g during inversion periods. These peak levels can occur in all seasons and can be independent of regional air quality. The most significant local source factors from the PMF analysis (Appendix C

- 2) are industrial carbons, influenced strongly by inversion s, with the highest contributions from the southwest of the Liberty monitor. While other source factors are evident and can lead to both long

- term and short

- term impacts, exceedance levels can be most attributed to local industrial

carbons sources.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 99

51. Comm ent: The SIP represents a step forward in the continued improvement of our region’s air quality. However, continued attention is needed to ensure future environmental regulations do not disproportionately impact economic development and that the burden o f emissions reductions is not unfairly shouldered by select industries or organizations. The contingency plan’s only course of action should the area fail to come into attainment is to wrest further reductions from the U. S. Steel Clairton facility. But, many emission sources, including alternative home heating sources, out

- of

- region transport, and vehicle traffic contribute to the area’s pollutants.

Commenter : Greater Pittsburgh Chamber of Commerce.

Response : See response to previous comment. A cont ingency measure is not necessarily a remedy to a nonattainment situation but rather a starting point that allows for reductions to take place while a new overall plan is developed.

WEIGHT OF EVIDENCE Comments related to the supporting evidence used to show that the Liberty

- Clairton area shows decreasing trends of PM 2.5 .

52. Comment: ACHD should address if a switch to natural gas for diesel

- burning equipment is foreseeable, and if this shift would affect local/regional PM 2.5

.

Commenter : U.S. EPA Region III.

Response : Any switches to natural gas from diesel would lower the carbon contributions from stationary or mobile sources. Possible increases in NO

x from increased natural gas usage would not likely affect PM 2.5 concentrations in the Liberty

- Clairto n area, as nitrates make up only a small portion of the localized excess at Liberty. Additionally, regional increases of upwind NO

x due to shale gas production in the future modeled case showed little apparent effect on the future case PM 2.5 impacts in Li berty

- Clairton.

53. Comment: The SIP should mention the potential benefits associated with the EPA Boiler MACT rules promulgated on January 13, 2013.

Commenter : U. S. Steel Corporation.

Response : The Boiler MACT and other federal MACT rules were include d as on

- the

- book

controls in the MANE

- VU inventories. The weight of evidence section focused on rules or other supporting factors that were not included in the modeling inventories.

54. Comment: The SIP mentions wood stoves and wood

- fired boilers regulatio ns that provide particulate reductions, but U. S. Steel is concerned with the difficulty in locating these sources andLiberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 100

proper enforcement of the regulations. U. S. Steel is also concerned about the ability to enforce

anti

- idling regulations.

Commenter : U. S. Steel Corporation.

Response : ACHD maintains an enforcement staff that includes full

- time field inspectors that investigate potential air quality violations in response to complaints or based on personal

observations. Local law enforcement and PA D EP enforce idling regulations in the state of

PA.

Furthermore, the wood stove and outdoor wood

- fired boilers programs result in the manufacturing and sales of cleaner

- burning units, independent of the location of units. To

address wood

- burning units not covered by these programs, ACHD has implemented an emission mitigating “clean

- burning” educational campaign to proactively reduce wood

smoke emissions.

55. Comment: Emissions reduction measures listed in the weight of evidence section may be relied upon onl y if they are federally enforceable.

Commenter : Clean Air Council et al.

Response : The weight of evidence section is based on qualitative evidence that the Liberty

Clairton area will incur reductions that were not incorporated in the modeling demonstra tion. This can include population trends, local programs, and other factors that lead to reductions that were not included in the control strategy or quantified in the modeled inventories. These factors need not be federally enforceable.

56. Comment: Sect

ion 9.7 regarding the monitored data during low productions periods should be examined by individual year, correlating changes in emission rates with monitored data. Additionally, subtracting Lawrenceville averages from Liberty may not be a valid techniqu e for examining local vs. regional trends.

Commenter : Clean Air Council et al.

Response : The monitored data during low production was provided as weight of evidence to show that low production levels yielded real

- world changes in monitored data, simila r to the expected modeling reductions. Individual years were not examined as year 2009 experienced much lower levels of production than in previous years. However, air quality has continued to improve after 2009. Additionally, the Lawrenceville site was used to represent regional

PM 2.5 concentrations since it is the only other continuous PM 2.5 site in Allegheny County.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 101

Notes on commenters :

 U.S. EPA Region III comments were submitted by Diana Esher, Director, Air Protection Division, U.S. EPA Region III.

 Greater Pittsburgh Chamber of Commerce comments were submitted by Barbara McNees, President, Greater Pittsburgh Chamber of Commerce.

 U. S. Steel Corporation comments were submitted by Coleen M. Davis, Senior Environmental Engineer, U. S. Steel.

 Clean Water Action comments were submitted by Tom Hoffman, Western Pennsylvania Director, Clean Water Action.

 Clean Air Council et al. comments were collaborative comments from Clean Air Council (Council), Citizens for Pennsylvania’s Future (PennFuture), Group Against Smog and Pollution (GASP), Clean Water Action, Sustainable Pittsburgh, Sierra Club, Residents for a Clean and Healthy (REACH) Mon Valley, and Center for Coalfield Justice, signed by the following:

o Joseph Otis Minott, Esq., Executive Directo r, Clean Air Council

o Tom Hoffman, Western Pennsylvania Director, Clean Water Action

o Heather Langeland, Esq., Staff Attorney, PennFuture

o Joe Osborne, Esq., Legal Director, Group Against Smog and Pollution

o Court Gould, Executive Director, Sustainable Pittsbu rgh

o Randy Francisco, Pennsylvania Organizing Representative, Sierra Club

o REACH Mon Valley

o Joanne Kilgour, Esq., Legal Director, Center for Coalfield Justice

Contributors to these comments also included the following:

o Khanh Tran, Principal, AMI Environmen tal, on behalf of Clean Air Council

o William Charlton, on behalf of Citizens for Pennsylvania’s FutureLiberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 102



### 11.5 Certification of AdoptionLiberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 103



## References

Abt Associates Inc. (201 2 ). Modeled Attainment Test Software User’s Manual

. Prepared for U.S. EPA, Office of Air Quality Planning and Standards

. Available at: http://www.epa.gov/ttn/scram/guidance/guide/MATS

- 2

- 5

- 1_manual.pdf

Allegheny County Health Department (ACHD) (2012). PM 2.5 Modeling Protocol, 2006 PM 2.5 Standards, Liberty

- Clairton Nonattainment Area

. Air Quality Program.

Allegheny County Health Department (ACHD) (2008). Installation Permit 0052

- I011 for U. S. Steel C Battery

.

Allegheny County Health Department (ACHD) (2011). Installation Permit 0052

- I01 4 for U. S. Steel Quench Towers 5A and 7A

.

ASTM International (2010). Standard D6589

- 05, “Standard Guide for Statistical Evaluation of Atmospheric Dispersion Model Performance,” Annual Book of ASTM Standards , Section 11, “Water and Environmental Technology,” Volume 11.07, “At mospheric Analysis. ”

Desert Research Institute (2005). Source Apportionment Analysis of Air Quality Monitoring
Data: Phase II . Prepared for the Mid

- Atlantic/Northeast Visibility Union and Midwes t Regional Planning Organization. Available at: http://www.ladco.org/reports/rpo/data_analysis/source_apportionment _study_of_improve_data_p hase_ii_draft_final_report_dri.pdf

ENSR Corporation (2008). Installation Permit Application for the Proposed C Battery Project . Prepared for United States Steel Corporation.

ENVIRON International Corporation (2011). User’s Guide, C omprehensive A ir quality M odel

with e x tensions, Version 5.40 . CAMx model. Available at: http://www.camx.com/files/camxusersguide_v5

- 40.aspx

Fox, T. (201 1 ). “ Update to the 24

- Hour PM2.5 NAAQS Modeled Attainment Test .”

Memorandum. U.S. EPA, Office of Air Quality Planning and Standards. June 28

. Available at:

ht tp://www.epa.gov/scram001/guidance/guide/Update_to_the_24

- hour_PM25_Modeled_Attainment_Test.pdf

Karamchandani, P., Vijayaraghavan, K., & Yarwood, G. Sub

- grid scale plume modeling. Atmosphere

. 2 , 389

- 406. 2011. Available at: http://www.mdpi.com/2073

- 4433/2/3/389

McNally, D. & Loomis, C. (2012). Application and Evaluation of WRF for Calendar Year 2007

. Prepared for Allegheny County Health Department by Alpine Geophysics, LLC.

Northeast States for Coo rdinated Air

- Use Management (NESCAUM) (2006). The Nature of the Fine Particle and Regional Haze Air Quality Problems in the MANE

- VU Region: A Conceptual Description

. Available at: http://www.nescaum.org/topics/regional

- haze/regional

- haze

documentsLiberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 104

Page, S. D. (2012). “Implementation Guidance for the 2006 24

- Hour Fine Particle (PM2.5)
National Ambient A ir Quality Standards (NAAQS).” Memorandum. U.S. EPA, Office of Air Quality Planning and Standards. March 2. Available at: http://www.epa.gov/ttn/naaqs/ pm/pdfs/20120302_implement_guidance_24

- hr_pm2.5_naaqs.pdf

Robinson, A. L., Khlystov, A., Wittig, B., Davidson, C. I., & Pandis, S. N. (2003). Characteristics and Sources of PM 2.5 in the Pittsburgh Region

. , Carnegie Mellon University.
Available at: http://www.netl.doe.gov/publications/proceedings/02/air_q3/CMU.pdf

Sullivan Environmental Consulting, Inc. (2007). The Processing of CALMET Files for Allegheny County’s PM2.5 SIP Analysis . Prepared for Allegheny County Health Dept.

Sullivan Environmental Consulting, Inc. (1996). Review of Meteorology at the Clairton Area: Strengthening Dispersion Modeling for State Implementation Plans . Prepared for Allegheny County Health Dept.

TranSystems|E.H. Pechan & Associates, Thompson G. Pace, and Michael Baker Jr. Inc. (2012). 2007 and 2014 Liberty

- Clairton PM 2.5 Nonattainment Area Emission Inventories and Source Assessment Analysis . Prepared for Allegheny County Health De partment

.

U.S. EPA (2011). Air Quality Modeling: Final Rule Technical Support Document [for the
Transport Rule ( CSAPR ) ] . Available at: http://www.epa.gov/airtransport/pdfs/AQModeling.pdf

U.S. EPA (2011). Update to the 24 Hour PM 2.5 NAAQS Modeled Attainment Test. Available at: http://www.epa.gov/scram001/guidance/guide/Update_to_the_24

- hour_PM25_Modeled_Attainment_Test.pdf

U.S. EPA (2007). Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for Ozone, PM 2.5 , and Regional Haze. EPA

- 454/B

- 07

- 002.
Available at: http://www.epa.gov/scram001/guidance/guide/final

- 03

- pm

- rh

- guidance.pdf

U.S. EPA (2006). Definition of SANDWICHed STN Data. Available o n EPA’s Air Explorer web page : www.epa.gov/mxplorer/sandwich_description.doc

U.S. EPA (2006). Area Designations for 2006 24

- Hour PM 2.5 NAAQS

– Technical Information web page: http://www.epa.gov/ttn/naaqs/pm/pm25_2006_techinfo.html

U.S. EPA (2005). Emissions Inventory Guidance for Implementation of Ozone and Particulate Matter National Ambient Air Quality Stan dards (NAAQS) and Regional Haze Regulations . EPA

454/R

- 05

- 001. August, updated November. Available at: http://www.epa.gov/ttnchie1/eidocs/eiguid/index.html

U.S. EPA (1992). "State Impl ementation Plans; General Preamble for the Implementation of Title I of the Clean Air Act Amendments of 1990," Proposed Rule, 57 Federal Register
13,498. Information at: http://www. epa.gov/airquality/urbanair/sipstatus/index.html

U.S. EPA, Region III (2012)

. Updated R Analysis for the Liberty

- Clairton PM

- 2.5
Nonattainment Area . Air Quality Analysis Branch.Liberty

- Clairton PM 2.5 SIP Revision, 2006 Stds. May 10, 2013 Page 105

U.S. EPA, Region III (2008). Designation Response Letter to the Honorable Edward G. Rendell

, and Addendum 2. Available at: http://www.epa.gov/pmdesignations/2006standards/rec/region3R.htm