# dep

west virginia department of environmental protection
Executive Office 60 I 57'h ST SE Charleston, WV 24304

Mr. Shawn M. Garvin (3RAOO) Regional Administrator US EPA Region 3 1650 Arch Street Philadelphia, P A 19103-2029 April 13, 2012 Earl Ray Tomblin, Governor Randy C. Huffman, Cabinet Secretary www.dep.wv.gov

Re: Redesignation Request and Maintenance Plan for the West Virginia Portion of the Steubenville-Weirton, OH-WV 1997 PM 2

. 5 Nonattainment Area

Dear Administrator Garvin:

The State of West Virginia is requesting that EPA redesignate the West Virginia portion of the Steubenville-Weirton, OH-WV 1997 PM2.s Nonattainment Area to attainment pursuant to the provisions of the Clean Air Act, Section 107. The State is also asking that EPA concurrently approve, as a revision to the State Implementation Plan (SIP), the related CAA, Section 175A maintenance plan which demonstrates that the area will continue to meet the PM 25 air quality standards for at least ten more years.
The request is detailed in the enclosed hardcopy: Redesignation Request and Maintenance Plan for the West Virginia Portion ofthe Steubenville-Weirton, OH-WV 1997 PM2.5 Nonattainment Area and the supporting documentation is provided in electronic format, on the enclosed compact discs. We certify that the electronic copies include exact duplicates of the hard copy. The electronic copies also furnish additional information which has not been presented in hardcopy form. We certify that the public hearing required by 40 CFR §51.102(a) was held in accordance with the applicable state laws and the requirements of 40 CFR §51.1 02( d). EPA and the state of Ohio were notified at the beginning of the public comment period. Please contact John Benedict, Director, Division of Air Quality at (304) 926-0462, if you have any questions or need additional information.

Enclosures

cc: Diana Esher (3APOO) John Benedict

# ~ Cabinet Secretary

Promoting a healthy environment.west virginia department of environmental protection



# REDESIGNATION REQUEST AND MAINTENANCE PLAN FOR THE WEST VIRGINIA PORTION OF THE STEUBENVILLE-WEIRTON, OH-WV

1997 PM 2.5 

# NONATTAINMENT AREA

FINAL April 2012

Promoting a healthy environment.Page intentionally left blank.

Page iiTable of Contents

I. INTRODUCTION

..................................................... Page 1 A. Request . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 1 B. Background

....................................................... Page 1 C. Geographic Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 2

II. REDESIGNATION CRITERIA

.......................................... Page 3 A. The Weirton Area has attained the 1997 PM 2.5 Standard . . . . . . . . . . . . . . . . . . . . Page 3 B. The Weirton Area has a Fully Approved SIP Under Section 110(k) of the CAA . . Page 8 C. The Weirton Area’s Air Quality Improvement is Due to Permanent and Enforceable Emissions Reductions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 9 D. The State has Developed a Maintenance Plan for the Weirton Area Which Ensures Attainment of the 1997 PM 2.5 Standard for at least 10 Years . . . . . . . . . . . . . . . . . Page 9 E. The Weirton Area Has Met All Relevant Requirements under CAA Section 110 and Part D................................................................ Page 9 1. Section 110(a) requirements

....................................... Page 9 2. Section 172(c) requirements

...................................... Page 10 3. Conformity

.................................................... Page 10

III. MAINTENANCE PLAN

............................................ Page 11 A. PM 2.5 Emissions Demonstrations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 15 B. NO x Emissions Demonstrations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 17 C. SO 2 Emissions Demonstrations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 19 D. Summary of PM 2.5 , NO x , and SO 2 Emission Reductions . . . . . . . . . . . . . . . . . . . . Page 21 E. Air Quality Improvement is Based on Permanent and Enforceable Emission Reductions

................................................................ Page 22 F. Emissions Tracking . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 23

IV. TRANSPORTATION ANALYSIS

...................................... Page 24 A. Onroad Emission Estimations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 24 B. Onroad Mobile Emissions Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 25 C. Emissions Model . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 25 D. Temperature and Relative Humidity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 26 E. Onroad Mobile Emission Estimations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 28

V. CONTROL MEASURES AND REGULATIONS

........................... Page 35 A. Reasonably Available Control Measures (RACM) and Reasonably Available Control Technology (RACT)

............................................... Page 35 B. Inventory of Actual Emissions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 36 C. Evidence that control measures required in past PM 2.5 SIP revisions have been fully implemented. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 36 1. NO x SIP Call, CAIR and CSAPR

.................................. Page 36

Page iii Weirton, WV 1997 PM 2.5 Redesignation and Maintenance Plan2. Tier II Emission Standards for Vehicles and Gasoline Sulfur Standards

.... Page 37 3. Heavy-Duty Diesel Engines

....................................... Page 38 4. Clean Air Non-road Diesel Rule

................................... Page 38 D. Assurance that existing control measures will remain in effect

.............. Page 38

VI. SUPPLEMENTAL MODELING ANALYSES

.......................... Page 39 A. EPA Modeling for the Cross State Air Pollution Rule (Final Transport Rule) . . . Page 39 B. EPA Modeling for Proposed Transport Rule 2010

........................ Page 41 C. VISTAS/ASIP Emissions and Air Quality Modeling to Support PM 2.5 and 8-hour Ozone State Implementation Plans . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 42 D. EPA’s CAIR Modeling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 44

VII. CONTINGENCY MEASURES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 46 A. Maintenance Plan Review . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 46 B. Corrective Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 46 1. Warning Level Response

......................................... Page 46 2. Action Level Response

.......................................... Page 46 3. Control Measure Selection and Implementation

....................... Page 47 C. Potential Contingency Measures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 47 D. PM 2.5 , SO 2 , and NO x sources potentially subject to future additional control requirements.

................................................................ Page 47

VIII. PUBLIC PARTICIPATION

......................................... Page 48

IX. CONCLUSIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 49

Page iv Weirton, WV 1997 PM 2.5 Redesignation and Maintenance PlanList of Tables Table 1: Weirton Nonattainment Area Design Values for the 1997 Annual and 24-hr PM 2.5 NAAQS

............................................................. Page 4 Table 2: Reductions in SO 2 and NO x EGU Emissions Between 2008 and 2010

........ Page 12 Table 3: Brooke County, WV PM 2.5 Emission Inventory Totals for 2005, 2008, 2015 and 2025 (tpy) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 15 Table 4: Hancock County, WV PM 2.5 Emission Inventory Totals for 2005, 2008, 2015 and 2025 (tpy) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 16 Table 5: Jefferson County, OH PM 2.5 Emission Inventory Totals for 2005, 2008, 2015 and 2025 (tpy) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 16 Table 6: Weirton Nonattainment Area PM 2.5 Emission Inventory Totals for 2005, 2008, 2015 and 2025 (tpy)

.......................................................... Page 17 Table 7: Brooke County, WV NO x Emission Inventory Totals for 2005, 2008, 2015 and 2025 (tpy) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 17 Table 8: Hancock County, WV NO x Emission Inventory Totals for 2005, 2008, 2015 and 2025 (tpy) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 18 Table 9: Jefferson County, OH NO x Emission Inventory Totals for 2005, 2008, and 2015 and 2025 (tpy)

........................................................... Page 18 Table 10: Weirton Nonattainment Area NO x Emission Inventory Totals for 2005, 2008, 2015 and 2025 (tpy)

........................................................... Page 19 Table 11: Brooke County, WV SO 2 Emission Inventory Totals for 2005, 2008, 2015 and 2025 (tpy) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 19 Table 12: Hancock County, WV SO 2 Emission Inventory Totals for 2005, 2008, 2015 and 2025 (tpy) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 20 Table 13: Jefferson County, OH SO 2 Emission Inventory Totals for 2005, 2008, 2015 and 2025 (tpy) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 20 Table 14: Weirton Nonattainment Area SO 2 Emission Inventory Totals for 2005, 2008, 2015 and 2025 (tpy)

........................................................... Page 21 Table 15: West Virginia Portion of the Weir ton Area Comparison of 2008 attainment year and 2015 and 2025 projected emission estimates (tpy)

........................... Page 21 Table 16: Ohio Portion of the Weirton Area Comparison of 2008 attainment year and 2015 and 2025 projected emission estimates (tpy)

................................... Page 21 Table 17: Weirton Area Comparison of 2008 attainment year and 2015 and 2025 projected emission estimates (tpy) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 22 Table 18: Weirton Area Comparison of 2005 Base Year and 2008 Attainment Year Reductions by Sector . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 23 Table 19: MOVES Inputs

................................................. Page 27 Table 20: Brooke County, WV Emissions Estimations for Onroad Mobile Sources

.... Page 28 Table 21: Hancock County, WV Emissions Estimations for Onroad Mobile Sources . . . Page 28 Table 22: Summary of West Virginia Emissions Estimations for Onroad Mobile Sources

................................................................... Page 28 Table 23: Jefferson County, OH Emissions Estimations for Onroad Mobile Sources . . . Page 29Table 24: Emissions Estimate Totals for the Onroad Mobile Source Sector for the SteubenvilleWeirton, OH-WV Area

................................................ Page 29

Page v Weirton, WV 1997 PM 2.5 Redesignation and Maintenance PlanTable 25: Percentage of Steubenville-Weirton, OH-WV Emissions Attributable to Mobile Sources in 2005, 2008, 2015 and 2025

.................................... Page 30 Table 26: CSAPR Annual PM 2.5 Design Values (μg/m3) . . . . . . . . . . . . . . . . . . . . . . . . Page 40 Table 27: Proposed Transport Rule Modeling Results from EPA - 2010

............. Page 41 Table 28: VISTAS/ASIP 2009, 2012 and 2018 Modeling Results (with CAIR)

....... Page 43 Table 29: EPA CAIR Modeling Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 44

Page vi Weirton, WV 1997 PM 2.5 Redesignation and Maintenance PlanList of Figures Figure 1: Map of the Steubenville-Weirton, OH-WV nonattainment area and monitor locations

.................................................................... Page 4 Figure 2: West Virginia PM 2.5 Annual Design Values, 1999-2001 through 2008-2010. . . Page 6 Figure 3: Ohio PM 2.5 Annual Design Values, 1999-2001 through 2007-2009.

......... Page 7 Figure 4: PM 2.5 Annual Mean National Trends

................................. Page 8 Figure 5: Steubenville-Weirton, OH-WV non-attainment area

.................... Page 24 Figure 6: Steubenville-Weirton, OH-WV NAA NO x Emissions by Sector . . . . . . . . . . . Page 32 Figure 7: Steubenville-Weirton, OH-WV NAA PM 2.5 Emissions by Sector . . . . . . . . . . . Page 32 Figure 8: Steubenville-Weirton, OH-WV NAA SO 2 Emissions by Sector . . . . . . . . . . . . Page 33 Figure 9: Onroad NO x Emissions Tons per Year . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 34

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Page viii Weirton, WV 1997 PM 2.5 Redesignation and Maintenance PlanList of Appendices

Appendix A: Air Monitoring Data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page A - 1 Appendix B: Emissions Inventory . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page B - 1 Appendix C: On-Road Mobile Emissions Inventory Documentation . . . . . . . . . . . . . Page C - 1 Appendix D: LADCO Documentation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page D - 1 Appendix E: Federal Consent Decrees and State Consent Orders . . . . . . . . . . . . . . . Page E - 1 Appendix F: Public Participation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page F - 1 Appendix G: Jefferson County, Ohio Emissions Inventory Summary . . . . . . . . . . . . Page G - 1

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Page x Weirton, WV 1997 PM 2.5 Redesignation and Maintenance PlanREDESIGNATION REQUEST AND MAINTENANCE PLAN FOR THE WEST VIRGINIA PORTION OF THE STEUBENVILLE-WEIRTON, OH-WV 1997 PM 2.5 NONATTAINMENT AREA

I. INTRODUCTION The Steubenville-Weirton, OH-WV PM 2.5 nonattainment area (Weirton area) is a multi-state nonattainment area, comprising Brooke and Hancoc k Counties in West Virginia, and Jefferson County in Ohio. The area monitored attainment of the 1997 PM 2.5 standard with a design value for 2007-2009 of 14.4 μg/m 3 , 2008-2010 of 13.7 μg/m 3 and 2009-2011 of 13.0 μg/m 3 . The State of West Virginia herein requests redesignation by the United States Environmental Protection Agency of Brooke and Hancock Counties to attainment relative to the 1997 PM 2.5 National Ambient Air Quality Standard. The State of Ohio also plans to request redesignation of Jefferson County, Ohio to attainment relative to the 1997 PM 2.5 National Ambient Air Quality Standard. A. Request The State of West Virginia is requesting that the United States Environmental Protection Agency (EPA) redesignate the West Virginia Portion of the Steubenville-Weirton, OH-WV 1997 PM 2.5 Nonattainment Area to attainment pursuant to the provisions of the Clean Air Act, section 107. The State is also requesting that EPA concurrently appr ove the associated maintenance plan as a revision to the State Implementation Plan (SIP), meeting the requirements of Clean Air Act, section 175A, which demonstrates that the area will continue to meet the current PM 2.5 air quality standards for at least ten more years. B. Background The Clean Air Act (CAA) requires areas failing to meet a Nationa l Ambient Air Quality Standard (NAAQS) to develop State Implementation Plans (SIPs) to expeditiously attain and maintain the standard. The EPA revised the NAAQS for particul ate matter in July 1997. It replaced the existing PM 10 standard with a health based PM 2.5 standard and retained the PM 10 standard as a “coarse” standard protecting welfare. The 1997 PM 2.5 standards include an annual standard set at 15.0 micrograms per cubic meter (μg/m 3 ), based on the 3-year average of annual mean PM 2.5 concentrations and a 24-hour standard of 65 μg/m 3 , based on the 3-year average of the 98 th percentile of 24-hour concentrations. The revised NAAQS were legally challenged in the U.S. Court of Appeals for the District of Columbia Circuit (D.C. Circuit). On May 14, 1999, th e D.C. Circuit remanded, without vacatur, the standard back to EPA. The remand did not ques tion the level at which EPA set the standards but rather the constitutionality of the CAA provision that authorizes EPA to set national air quality standards. EPA requested a reh earing which the D.C. Circuit denied. Therefore, in December 1999, EPA appealed the D.C. Circuit decision to the U.S. Supreme Court. The U.S. Supreme Court issued a decision on February 27, 2001 that unanimously affirmed the constitutionality of the CAA provision but did remand several other issues back to the D.C. Circuit, including the issue of whether EPA acted arbitrarily and capriciously in establishing the specific levels of the standards.

Page 1 Weirton, WV 1997 PM 2.5 Redesignation and Maintenance PlanThe D.C. Circuit heard arguments in this rema nded case in December 2001, and issued its decision on March 26, 2002. The court rejected the claims that the EPA had acted arbitrarily and capriciously in setting the levels of the standards. On December 17, 2004, EPA promulgated the initial PM 2.5 nonattainment areas designations for the PM 2.5 standards across the country. Modifications to those designations were made and an effective date was set at April 5, 2005. Unlike Subpart 2 of the CAA Amendments of 1990 which defined five ozone nonattainment classifications for the areas that exceed the NAAQS based on the severity of the ozone levels, PM 2.5 nonattainment designations are simply labeled “nonattainment.” The CAA Amendments require states with PM 2.5 nonattainment areas to submit a pl an within three years of the effective date of the designations (April 5, 2008) detailing how the PM 2.5 standards would be attained by April 5, 2010. On September 14, 2011 [76 FR 56641] EPA determined that the Steubenville-Weirton, OH-WV area had attained the 1997 PM 2.5 NAAQS (Clean Data Determination). This determination was based on complete, quality-assured and certified ambient air monitoring data for the three year periods, 2007- 2009 and 2008-2010. EPA also determined, in accordance with EPA’s PM 2.5 Implementation Rule of April 25, 2007 [72FR20664], that the area had attained the 1997 annual PM 2.5 NAAQS by the applicable attainment date of April 5, 2010. This determination suspended the state’s requirement to submit an attainment demonstration, Reasonably Available Control Measures (RACM), including Reasonably Available Control Technology (RACT) , Reasonable Further Progress (RFP) plan, contingency measures, and other planning SIP revisions related to attainment of the 1997 PM 2.5 NAAQS for so long as the area continues to attain the 1997 PM 2.5 NAAQS. C. Geographic Description The Steubenville-Weirton, OH-WV PM 2.5 nonattainment area (Weirton area) is a multi-state nonattainment area, comprising Brooke and Hancock Counties in West Virginia, and Jefferson County in Ohio. This area is shown in Figure 1 under Section II.A. The Weirton area has not previously been subject to nonattainment area rulemakings for fine particles. Although EPA designated the Weirton area nonattainment for the 15.0 μg/m 3 annual standard, as a result of the Clean Data Determination West Virg inia DEP was not required to develop a plan to reduce oxides of nitrogen (NO x ), sulfur dioxide (SO 2 ) and direct PM 2.5 emissions and demonstrate that the area would meet the federal annual air quality standard by April 5, 2010. This document is intended to support West Virginia’s request that the West Virginia portions of the Weirton area be redesignated from nonattainment to attainment for the 1997 PM 2.5 standard. In addition, the State of Ohio also plans to submit a request for their portion of the Weirton area.

Page 2 Weirton, WV 1997 PM 2.5 Redesignation and Maintenance PlanII. REDESIGNATION CRITERIA Pursuant to Section 107(d)(3)(E) of the CAA states must sufficiently address five issues to obtain redesignation of a nonattainment area to attainment: A. determinate that the area has attained the applicable NAAQS; B. have a fully approved implementation plan under CAA section 110(k); C. show that the improvement in air quality is due to permanent and enforceable emission reductions; D. submit an EPA approvable maintenance plan which ensures attainment of the NAAQS for at least ten years beyond redesignation; and E. show that the area has met the applicable requirements of CAA section 110 and part D. The State of West Virginia herein affirmatively comp letes all five of the required elements as detailed below.

A. The Weirton Area has attained the 1997 PM 2.5 Standard [See Appedix A] The following information is taken from EPA’s “Guideline on Data Handling Conventions for the PM NAAQS,” U.S. EPA-454/R-99-008, April 1999. In accordance with the CAA Amendments, three comp lete years of monitoring data are required to demonstrate attainment at a monitoring site. The annual PM 2.5 primary and secondary ambient air quality standards are met at an ambient air quality m onitoring site when the three-year average of the annual average is less than 15.0 μg/m 3 . While calculating design valu es, three significant digits must be carried in the computations, with final values rounded to the nearest 0.1 μg/m 3 . Decimals 0.05 or greater are rounded up, and those less th an 0.05 are rounded down, so that 15.049 μg/m 3 is the largest concentration that is less than, or equal to 15.0 μg/m 3 . Values at or below 15.0 μg/m 3 meet the standard; values equal to or greater than 15.1 μg/m 3 exceed the standard. An area is in compliance with the annual PM 2.5 NAAQS only if every monitoring site in the area meets the NAAQS. An individual site’s 3-year average of the annual averag e concentrations is also called the site’s design value. The air quality design value for the area is the highest design value among all sites in the area. There are five (5) monitors measuring PM 2.5 concentrations in the Weirton, OH-WV nonattainment area. Three (3) monitors are located in West Virg inia and operated by the West Virginia Division of Air Quality (DAQ). Two (2) of the monitors are located in Ohio and operated by the Ohio Environmental Protection Agency (OEPA). Th e location of the monitoring sites for this nonattainment area are shown in Figure 1. A listing of the design values based on the three-year average of the annual mean concentrations from 2001-2003 through 2009-2011 for the West Virginia monitors is shown in Table 1. The data for all five monitors is located in Appendix A. The data in Appendix A has been quality a ssured, up through 2010 in accordance with 40 CFR 58.10 and all other federal requirements. The data has b een recorded in the AQS database and, therefore, the data are available to the public. Table 1 shows the monitoring data for 2001-2010 that were

Page 3 Weirton, WV 1997 PM 2.5 Redesignation and Maintenance Planretrieved from the EPA AQS, and preliminary 2011 data that will be certified and recorded in the AQS database in accordance with 40 CFR 58.10.

Figure 1: Map of the Steubenville-Weirton, OH-WV nonattainment area and monitor locations

Table 1: Weirton Nonattainment Area Design Values for the 1997 Annual and 24-hr PM 2.5 NAAQS 1997 NAAQS 24 hr 3 yr 98% = 65 1997 Annual NAAQS = 15

FRM Site 01

- 03 02

- 04 03

- 05 04

- 06 05

- 07 06

- 08 07

- 09 08

- 10 09

- 11 01

- 03 02

- 04 03

- 05 04

- 06 05

- 07 06

- 08 07

- 09 08

- 10 09

- 11

54- 009- 0005 42 44 42 40 37 37 34 31 27 16.8 16.5 16.8 16.4 16.4 15.4 14.4 13.7 13.0

54- 009- 0011 46 47 45 43 44 41 37 31 29 16.2 15.8 16.4 15.7 16.1 14.9 14.0 13.1 11.6

54- 029- 1004 45 44 41 40 41 36 35 31 28 17.4 17.0 16.6 15.4 15.2 14.3 13.4 12.4 11.7 Source: EPA Air Quality System (AQS); http://www.epa.gov/ttn/airs/airsaqs/index.htm Notes: Green shading indicates meeting the standa rd, all monitors in the area monitor attainment. 2011 data is preliminary, and has not yet been certified.

Page 4 Weirton, WV 1997 PM 2.5 Redesignation and Maintenance PlanThe design values calculated for the Weirton area demonstrate that the 1997 PM 2.5 NAAQS has been attained. The area’s design values have trended downward as emissions have declined due to such factors as cleaner automobiles and fuels, and controls for EGUs, at the national, regional and local level. National monitoring for PM 2.5 began in 1999. There has been a clear downward trend in design values for all monitors in West Virginia and Oh io, as shown in Figures 2 and 3. Design values have also trended downward nationally, as shown in Figure 4. On September 14, 2011[76 FR 56641] EPA determined that the Steubenville-Weirton, OH-WV area had attained the 1997 PM 2.5 NAAQS [Clean Data Determination] . This determination was based upon complete, quality assured, quality controlled, and certified ambient air monitoring data that showed that the area monitored attainment of the 1997 PM 2.5 NAAQS during the 2007-2009 and 2008-2010 monitoring periods. EPA also determined that the Steubenville-Weirton, OH-WV area had attained the 1997 annual PM 2.5 NAAQS by the applicable attainment date of April 5, 2010. Preliminary PM 2.5 ambient air quality monitoring data for the recent three (3) year period 2009 through 2011, demonstrate that the air quality continues to meet the NAAQS for annual PM 2.5 in this nonattainment area. The NAAQS attainment, accompanied by decreases in emission levels discussed in Chapter Four, support a redesignation to attainme nt for the Weirton area based on the requirements in Section 107(d)(3)(E) of the CAA. DAQ commits to continue monitoring PM 2.5 levels at the West Virginia sites indicated in Figure 1 and Table 1. DAQ will consult with EPA Region III prior to making changes to the existing monitoring network, should changes become necessa ry in the future. DAQ will continue to quality assure the monitoring data to meet the requirement s of 40 CFR 58 and all other federal requirements. Connection to a central station and updates to th e DAQ web site will provide real time availability of the data and knowledge of any exceedances. DAQ will enter all data into AQS on a timely basis in accordance with federal guidelines.

Page 5 Weirton, WV 1997 PM 2.5 Redesignation and Maintenance PlanFigure 2: West Virginia PM2.5Annual Design Values, 1999-2001 through 2008-2010.Data Source:http://www.epa.gov/airtrends/values.html, from Excel spreadsheet: PM25dv20082010Final.xls1997 Annual Std = 15 ug/m3Page 6Weirton, WV 1997 PM2.5Redesignation and Maintenance PlanFigure 3: Ohio PM2.5Annual Design Values, 1999-2001 through 2007-2009.Data Source:http://www.epa.gov/airtrends/values.html, from Excel spreadsheet: PM25dv20082010Final.xls1997 Annual Std = 15 ug/m3Page 7Weirton, WV 1997 PM2.5Redesignation and Maintenance PlanFigure 4: PM 2.5 Annual Mean National Trends

Source: http://www.epa.gov/airtrends/pm.html B. The Weirton Area has a Fully Approved SIP Under Section 110(k) of the CAA On December 17, 2004, EPA promulgated the initial PM 2.5 nonattainment areas designations for the PM 2.5 standards across the country, including the St eubenville-Weirton, OH-WV area. Modifications to those designations were made and an effectiv e date was set at April 5, 2005. Unlike Subpart 2 of the CAA Amendments of 1990 which defined five oz one nonattainment classifications for the areas that exceed the NAAQS based on the se verity of the ozone levels, PM 2.5 nonattainment designations are simply labeled “nonattainment.” The CAA Amendments require states with PM 2.5 nonattainment areas to submit a plan within three years of th e effective date of the designations (April 5, 2008) detailing how the PM 2.5 standards would be attained by Ap ril 5, 2010. The DEP submitted a revision to the SIP for the State of West Virginia to meet its obligations under the CAA and the Federal Clean Air Implementation Rule for the Steubenv ille-Weirton, OH-WV area on June 24, 2009. The submittal expressly addressed the pertinent requirements of the CAA, Part D and the associated requirements of the Fine Particle Implementa tion Rule beginning at 40 CFR 51.1000. EPA notified the DEP that the SIP submittal was technically and administratively complete by letter dated November 10, 2009. Furthermore, On September 14, 2011, in accordance with Section 179(c)(1) of the CAA, EPA determined that the Steubenville-Weirton, OH-WV PM 2.5 nonattainment area had attained the 1997 annual PM 2.5 NAAQS by the applicable attainment date of April 5, 2010 [76FR56641]. This Clean Data Determination suspended the requirement for the state to submit an attainment demonstration, associated reasonably available control measures, a reasonable further progress plan, contingency measures, and other pla nning SIPs related to attainment of the standard
Page 8 Weirton, WV 1997 PM 2.5 Redesignation and Maintenance Planfor as long as the area continues to meet the 1997 PM 2.5 NAAQS. The DEP believes that all applicable requirements under CAA section 110(k) have been met. C. The Weirton Area’s Air Quality Improveme nt is Due to Permanent and Enforceable Emissions Reductions Several federally enforceable control measures have been implemented during the past decade which contribute to the air quality improvement, and will continue to reduce emissions in the future. These are discussed in detail in Section V - Control Measures and Regulations. D. The State has Developed a Maintenance Plan for the Weirton Area Which Ensures Attainment of the 1997 PM 2.5 Standard for at least 10 Years Section 107(d)(3)(E) of the CAAA stipulates that fo r an area to be redesignated to attainment EPA must approve a maintenance plan that meets th e requirements of Section 175A. A state may submit both the redesignation request and maintenance plan at the same time, and the plan adoption process, including rule-making or public hearing proceedings , may proceed on a parallel track. West Virginia is herein submitting a request to redesignate the Weirton area to attainment and is also requesting that EPA concurrently process this request and the accompanying maintenance plan. E. The Weirton Area Has Met All Relevant Requirements under CAA Section 110 and Part D For purposes of redesignation, a state must meet a ll requirements of Section 110 and Part D that were applicable prior to submittal of the complete redesignation request. Subpart 1 of Part D consists of general requireme nts applicable to all areas which are designated nonattainment based on a violation of the NAAQS. Subpa rt 4 of Part D consists of more specific requirements applicable to particulate matter (specifically to address PM 10 ). However, for the purpose of implementing the 1997 PM 2.5 standard, EPA’s Implementation Rule stated that Subpart 1, rather than Subpart 4, is appropriate for the purpose of implementing PM 2.5 .[72 FR 20589] 1. Section 110(a) requirements Section 110(a) of Title I of the CAA contains the general requirements for a SIP. Section 110(a)(2) provides that the implementation plan submitted by a state must have been adopted by the state after reasonable public notice and hear ing, and that, among other things, it must include enforceable emission limitations and other contro l measures, means or techniques necessary to meet the requirements of the CAA; provide for establishment and operation of appropriate devices, methods, systems and procedures necessa ry to monitor ambient air quality; provide for implementation of a source permit program to re gulate the modification and construction of any stationary source within the areas covered by the plan; include provisions for the implementation of Part C, prevention of significant deterior ation (PSD) and Part D, NSR permit programs; include criteria for stationary source emission control measures, monitoring, and reporting; include provisions for air quality modeling; and pr ovides for public and local agency participation in planning and emission control rule developm ent. In West Virginia’s December 11, 2007, and

Page 9 Weirton, WV 1997 PM 2.5 Redesignation and Maintenance PlanOctober 1, 2009 infrastructure SIP submissions and March 18, 2010 certification, West Virginia verified that the State fulfills the requirements of Section 110(a)(2) of the Act. Section 110(a)(2)(D) also requires State plans to prohibit emissions from within the State which contribute significantly to nonattainment or maintenance areas in any other State, or which interfere with programs under Part C to prevent significant deterioration of air quality or to achieve reasonable progress toward the national visibility goal for Federal class I areas (national parks and wilderness areas). In order to assist States in addressing their obligations regarding regionally transported pollution, EPA finalized CAIR to reduce SO 2 and NO x emissions from large electric generating units (EGU). West Virginia has met the requirements of the federal CAIR to reduce NO x and SO 2 emissions contributing to downwind states. On August 4, 2009, EPA approved West Virginia's CAIR progr am [74FR38536] , which were found in West Virginia’s Code of State Rules at 45 CSR39, 45CSR40, and 45CSR41. On July 6, 2010, EPA proposed a replacement to the CAIR program, th e Transport Rule [75 FR 45210]. The Transport Rule, or the Cross-State Air Pollution Rule (CSAPR) as it is now called, was finalized on July 6, 2011, and published in the Federal Register on August 8, 2011 [76FR48208]. Under the CSAPR, EPA adopted Federal Implementation Plans (FIPs) for each state covered by the rule, including West Virginia. The CSAPR further a ssists states in addressing their obligations regarding regionally transported po llution by providing reductions in NO x and SO 2 emissions in 2012 and 2014. On December 30, 2011 the United States Court of Appeals for the District of Columbia stayed the implementation of CSAPR, indefinitely reinstating CAIR. 2. Section 172(c) requirements Section 172(c) contains general requirements for nonattainment plans. The requirements for reasonable further progress, identification of certain emissions increases, and other measures needed for attainment will not apply for redesigna tions because they only have meaning for areas not attaining the standard. The requirements fo r an emission inventory will be satisfied by the inventory requirements of the maintenance plan. Sections III and V discuss these requirements in more detail. 3. Conformity The state must work with EPA to show that its SIP provisions are consistent with the Section 176(c)(4) conformity requirements. The redesignation request should include conformity procedures, if the state already has these procedur es in place. If a state does not have conformity procedures in place at the time that it submits a redesignation request, the state must commit to follow EPA’s conformity regulation upon issuance, as applicable. EPA approved West Virginia’s Transportation Conformity SIP detailing conform ity procedures effective June 2, 2008 [73 FR 24175].Section IV discusses this requirement in more detail.

Page 10 Weirton, WV 1997 PM 2.5 Redesignation and Maintenance PlanIII. MAINTENANCE PLAN (CAA Section 107(d)(3)(E)(iv)) Section 107(d)(3)(E) stipulates that for an area to be redesignated, EPA must fully approve a maintenance plan that meets the requirements of Section 175(A). The maintenance plan will constitute a SIP revision and must provide for ma intenance of the relevant NAAQS in the area for at least 10 years after redesignation. Section 175 (A) further states that the plan shall contain such additional measures, if any, as may be necessary to ensure such maintenance. In addition, the maintenance plan shall contain such contingency measures as the Administrator deems necessary to ensure prompt correction of any violation of the NAAQS . At a minimum, the contingency measures must include a requirement that the state will implement all measures contained in the nonattainment SIP prior to redesignation. In consultation with EPA and Ohio EPA, West Vi rginia DAQ selected the year 2025 as the end year of the maintenance plan for this redesignation re quest. This document contains projected emissions inventories for 2015 and 2025. Thus, the pertinent inventory years are: 2005 (nonattainment year), 2008 (attainment year and maintenance plan base year), 2015 (interim year) and 2025 (maintenance plan end year). Three specific emissions inventory demonstrations should be made: 1. The attainment year (2008) emissions of PM 2.5 , NO x and SO 2 must each be less than the corresponding emissions in the nonattainment year (2005). The reductions must be attributable to federally enforceable emissi on reductions (as discussed in Section III.E and Section V). 2. The interim year (2015) emissions of each of the three pollutants should be less than the maintenance plan base year (2008). 3. The end year (2025) emissions of each of the three pollutants should be less than the maintenance plan base year (2008). As can be seen in Table 2 below, West Virginia has seen a significant state-wide decline of the 467,081 tons of SO 2 and 159,481 tons of NO x emitted by EGUs in 2005. In 2008 and 2009, facilities began preparing for and implementing control programs to address CAIR and consent orders. Significant reductions occurred regionally and na tionally. Data available for 2010, show the SO 2 and NO x reductions which were implemented under CAIR.

Page 11 Weirton, WV 1997 PM 2.5 Redesignation and Maintenance PlanTable 2: Reductions in SO 2 and NO x EGU Emissions Between 2008 and 2010 SO 2 NO x 2008 2010 % Change 2008 2010 % Change West Virginia 301,574 106,088 -65% 97,331 51,393 -47% Ohio 709,444 570,045 -20% 235,018 104,574 -56% National 7,616,449 5,119743 -33% 2,996,594 2,061,062 -31% Source: Clean Air Markets, Data and Maps , Quick Reports, State Level Emissions Quick Report and Program Level Emissions Quick Report, Acid Rain Program Further, Tables 3- 18 clearly show total emissions from all sectors decreased in the period from 2005 to 2008 in the West Virginia and Ohio portions of the nonattainment area. As outlined below, the reductions are enforceable and should continue in the future. On March 10, 2004, EPA promulgated the CAIR. Beginning in 2009, EPA’s CAIR rule required EGUs in 28 eastern states and the District of Columbia to significantly reduce emissions of NO x and SO 2 . CAIR replaced the NO x SIP Call for EGUs. The intent of the CAIR program was for national NO x emissions to be cut from 4.5 million tons in 2004, to a cap of 1.5 million tons by 2009, and 1.3 million tons in 2018 in 28 states. St ates were required to submit a CAIR SIP as part of this effort. West Virginia DEP submitted a CAIR SIP to EP A on June 1, 2006. Revisions to the CAIR SIP were submitted on April 22, 2008. The revised CAIR SI P was approved on August 4, 2009 (74 FR 38536). As a result of CAIR, EPA project ed that in 2009 emissions of NO x would decrease from a baseline of 179,000 tons per year to 63,000 tons pe r year while in 2010 emissions of SO 2 would decrease from a baseline of 582,000 tons per year to 250,000 tons per year, within West Virginia. And by 2015, EPA projected emissions of NO x would decrease to 44,000 tons per year while emissions of SO 2 would decrease to 118,000 tons per year, within West Virginia. On December 23, 2008, EPA’s CAIR program was re manded without vacatur by the D.C. Circuit Court. The following was reported by EPA’s Clean Markets Division: “Based on emissions monitoring data, EPA has observed substantial reductions in emissions from 2005 to 2010 as companies installed more controls, electric demand declined, and low natural gas prices made combined-cycle gas-fi red units more competitive in several parts of the country. Thus, even after CAIR’s vacatur and subsequent remand in late 2008, the controls in place generally have continued to operate, helping to drive continued progress in reducing emissions. However, allowance prices of SO 2 have been relatively low since 2008, raising concerns that coal-fired units could burn dirtier fuels, operate scrubbers at reduced efficiency, or even bypass scrubbers altoge ther, instead relying on banked allowances (because there is not an existing large bank of NO x allowances, NO x allowance prices have not been affected as significantly). For these reasons, EPA is tracking SO 2 and NO x emissions closely each quarter to evaluate further pr ogress and assess whether backsliding may be Page 12 Weirton, WV 1997 PM 2.5 Redesignation and Maintenance Planoccurring and, if so, wher e it may be taking place.” [ http://www.epa.gov/airmarkets/background.htm ] On July 6, 2010, EPA proposed a replacement to the CAIR program, the Transport Rule [75 FR 45210]. On July 6, 2011, EPA finalized the Transport Rule, now commonly referred to as the CrossState Air Pollution Rule (CSAPR) [76 FR 48208, 08 AUG 2011] in time for reductions to begin in 2012. As finalized, the CSAPR will preserve the initial reductions achieved under CAIR and provide more reductions in NO x and SO 2 emissions in 2012 and 2014, ahead of the 2015 CAIR Phase 2. West Virginia DAQ is in agreement with the anal ysis by U.S. EPA that the CAIR program provided real reductions. We believe these reductions have assisted with PM 2.5 attainment in this nonattainment area and throughout West Virginia. It is also the DAQ’s belief that the CSAPR will continue to provide the necessary reductions, and likely even greater reductions, that will be necessary for maintenance of the annual PM 2.5 standard to continue. As stated by EPA regarding the final Transport Rule or CSAPR: This rule will prohibit all significant contri bution to nonattainment and interference with respect to the annual and 24-hour PM 2.5 . In addition, it will resolve air quality issues at most nonattainment and maintenance receptors iden tified by EPA. EPA projects that unresolved nonattainment and maintenance issues will remain in only a few downwind states after promulgation and implementation of the Transport Rule. For the annual PM 2.5 standard, EPA projects that this rule will help assure th at all areas in the east fully resolve their nonattainment and maintenance concerns. This ru le will also help a number of areas achieve the standard earlier than they may have otherwise. [76 FR 48247] However, on December 30, 2011 the United States Court of Appeals for the District of Columbia stayed the implementation of CSAPR, indefinitely reinstating CAIR. Although there are no electric generating units in the West Virginia portion of the SteubenvilleWeirton, OH-WV area, the DAQ believes that CA IR, or any likely repl acement for CAIR, will constrain nearby EGU NO x and SO 2 emissions sufficiently to ensure that maintenance level emissions are not exceeded during the maintenance period. As shown in Section VI - Supplemental Modeling Analyses, recent modeling -- CAIR, proposed Transport Rule, CSAPR (Final Transport Rule), including base cases where CAIR and CSAPR were not considered to be applicable requirements, and the VISTAS/ASIP modeling (which includes CAIR) -- all show that the Steubenville-Weirton, OH-WV area will continue to maintain the 1997 PM 2.5 NAAQS. Emission projections for the Weirton area were performed using the following approaches: • Emissions inventories are required to be project ed to future dates to assess the influence of future growth and controls. • NonEGU Point, Area, and Locomotive/Marine Source inventories for 2015 and 2025 were developed by DAQ based on the 2008 inventory using Workforce West Virginia economic forecasts (http://www.workforcewv.org/LM I/indproj/longterm/WV.htm ). The Workforce WV Page 13 Weirton, WV 1997 PM 2.5 Redesignation and Maintenance Planprojections were in terms of North American Industrial Classification System (NAICS) codes while the WV 2008 v1.5 data is in terms of S CCs. A list of SCCs contained in the 2008 WV inventory was compiled and the associated with each NAICS code for which there was a Workforce WV growth factor. Then directly proportional growth factors were calculated and applied to Workforce WV’s 2018 growth fact or to calculate 2015 and 2025 emissions. The final estimates reflect both positive and negative growth. The 2008 NEI data were downloaded from EPA’s CHIEF webpage at http://www.epa.gov/ttn/chief/ net/2008inventory.html

. • Nonroad mobile source inventories for those categories calculated by the model were developed by DAQ personnel using monthl y NONROAD Model runs for 2015 and 2025, and summing the monthly data to obtain annual data. • Ohio provided the emission estimates for the Ohio portion of the area, based on LADCO developed growth and control files for Poin t, Area, and Nonroad categories. Appendix D contains LADCO’s technical support document detailing the analysis used to project emissions (Base M ) [ www.ladco.org/tech/emis/current/index.php ]. • As performed by ODOT, Onroad mobile source emission projections are based on the EPA MOVES model. The analysis is described in more detail in Appendix C. All projections were made using federally approved interagency consultation procedures. As discussed in Section IV, DAQ determined that the mobile em ission contribution as a percent of the total emission inventory from the area is not significant. The detailed inventory information for the West Virginia portion of the Weirton area for 2005 is contained in Appendix B. Emission trends are an important gauge for continued compliance with the PM 2.5 standard. Therefore, West Virginia DAQ performed an initial comparison of the inventories for the base year and maintenance years. Sectors included for West Virginia in the follo wing tables are: Electrical Generating Unit (EGU); Non-Electrical Generating Units including Airports (Non-EGU); Non-road Mobile (Nonroad); Other Area (Area); Locomotive and Marine (LM); and Onroad Mobile (Onroad). Sectors included for Ohio in the following ta bles are: Electrical Generating Unit (EGU); Non-Electrical Generating Unit (Non-EGU); Non-ro ad Mobile (Nonroad); Other Area (Area); Marine; Aircraft; Rail (MAR); and Onroad Mobile (Onroad). Maintenance is demonstrated when the future-year (2025) projected emission totals of each of the relevant pollutants are below the 2008 attainment year totals. The West Virginia emissions data in the tables below are based on the following data sources: • All On-Road data developed by ODOT for WWW. • 2005 and 2008 EGU and non-EGU Point Source fr om certified data submitted by industry to West Virginia DAQ’s 2005 and 2008 annual emissions inventory database and subsequently submitted to EPA. • WV Nonroad data developed by DAQ using EPA’s Nonroad Model v2008.1.0.

Page 14 Weirton, WV 1997 PM 2.5 Redesignation and Maintenance Plan• All other West Virginia data developed by DAQ based on Workforce WV economic projections. • All Ohio data provided by OEPA.

A. PM 2.5 Emissions Demonstrations

The 2005 and 2008 actual PM 2.5 EGU and NonEGU emissions data below reflects PM 2.5 -primary emissions. Although some facilities reported both PM 2.5 -pri and the PM fraction emissions, not all facilities reported PM 2.5 -pri emissions. When PM 2.5 -pri was not reported by sources, WV DAQ applied PM augmentation procedures in accordance with EPA procedures as documented in EPA’s CSAPR technical support document (TSD), “ Emissions Inventory Final Rule TSD , June 28, 2011” and discussed in more detail in Appendix B a nd with further technical support provided by EPA’s Emission Inventory and Analysis Group (EIAG).
Table 3: Brooke County, WV PM 2.5 Emission Inventory Totals for 2005, 2008, 2015 and 2025 (tpy) Sector 2005 (Base) 2008 Attainment 2015 Interim 2015 Safety Margin 2025 Maintenance 2025 Safety Margin EGU 0 00 0 0 0 NonEGU 155 167 156 11 142 25 Area 208 220 218 2 216 4 LM 17 4 4 0 4 0 Nonroad 11 9 6 3 4 6 Onroad 19 14 7 7 4 10 TOTAL 411 414 391 24 370 45

Page 15 Weirton, WV 1997 PM 2.5 Redesignation and Maintenance PlanTable 4: Hancock County, WV PM 2.5 Emission Inventory Totals for 2005, 2008, 2015 and 2025 (tpy) Sector 2005 (Base) 2008 Attainment 2015 Interim 2015 Safety Margin 2025 Maintenance 2025 Safety Margin EGU 0 00 0 0 0 NonEGU 182 91 84 7 75 16 Area 314 233 230 3 230 3 LM 26 18 19 0 19 0 Nonroad 10 8 6 3 3 5 Onroad 19 14 7 7 4 9 TOTAL 550 364 345 19 331 33

Table 5: Jefferson County, OH PM 2.5 Emission Inventory Totals for 2005, 2008, 2015 and 2025 (tpy) Sector 2005 (Base) 2008 Attainment 2015 Interim 2015 Safety Margin 2025 Maintenance 2025 Safety Margin EGU 1,308 1,373 1,405 133 1,450 -77 NonEGU 462 461 438 24 414 48 Area 110 111 108 2 106 5 MAR 8 75 3 1 7 Nonroad 24 23 17 5 11 11 Onroad 73 61 32 29 16 44 TOTAL 1,985 2,036 2,005 30 1,998 38

Page 16 Weirton, WV 1997 PM 2.5 Redesignation and Maintenance PlanTable 6: Weirton Nonattainment Area PM 2.5 Emission Inventory Totals for 2005, 2008, 2015 and 2025 (tpy) County 2005 (Base) 2008 Attainment 2015 Interim 2015 Safety Margin 2025 Maintenance 2025 Safety Margin Brooke, WV 411 414 391 24 370 45 Hancock, WV 550 364 345 19 331 33 WV PM 2.5 Total 961 778 735 43 700 78 Jefferson, OH 1,985 2,036 2,005 30 1,998 38 Combined PM 2.5 Total 2,946 2,814 2,741 73 2,698 116

B. NO x Emissions Demonstrations
Table 7: Brooke County, WV NO x Emission Inventory Totals for 2005, 2008, 2015 and 2025 (tpy) Sector 2005 (Base) 2008 Attainment 2015 Interim 2015 Safety Margin 2025 Maintenance 2025 Safety Margin EGU 0 00 0 0 0 NonEGU 693 790 742 48 679 110 Area 311 119 118 1 116 3 LM 445 113 114 -1 115 -2 Nonroad 205 169 88 81 59 110 Onroad 540 412 175 237 62 350 TOTAL 2,194 1,603 1,237 367 1,032 572

Page 17 Weirton, WV 1997 PM 2.5 Redesignation and Maintenance PlanTable 8: Hancock County, WV NO x Emission Inventory Totals for 2005, 2008, 2015 and 2025 (tpy) Sector 2005 (Base) 2008 Attainment 2015 Interim 2015 Safety Margin 2025 Maintenance 2025 Safety Margin EGU 0 00 0 0 0 NonEGU 1,181 575 525 50 463 112 Area 1,447 158 157 1 115 3 LM 695 535 538 -3 543 -8 Nonroad 135 119 75 45 51 68 Onroad 483 360 149 211 52 308 TOTAL 3,942 1,747 1,443 304 1,264 483

Table 9: Jefferson County, OH NO x Emission Inventory Totals for 2005, 2008, and 2015 and 2025 (tpy) Sector 2005 (Base) 2008 Attainment 2015 Interim 2015 Safety Margin 2025 Maintenance 2025 Safety Margin EGU 41,047 35,487 19,488 15,999 12,632 22,855 NonEGU 1,992 1,992 1,939 53 1,864 128 Area 251 253 252 1 252 2 MAR 317 301 203 98 71 230 Nonroad 234 208 131 76 97 111 Onroad 2,106 1,758 870 888 323 1,435 TOTAL 45,947 39,999 22,884 17,115 15,238 24,761

Page 18 Weirton, WV 1997 PM 2.5 Redesignation and Maintenance PlanTable 10: Weirton Nonattainment Area NO x Emission Inventory Totals for 2005, 2008, 2015 and 2025 (tpy) County 2005 (Base) 2008 Attainment 2015 Interim 2015 Safety Margin 2025 Maintenance 2025 Safety Margin Brooke, WV 2,194 1,603 1,237 367 1,032 572 Hancock, WV 3,942 1,747 1,443 304 1,264 483 WV NO x Total 6,136 3,350 2,680 671 2,296 1,055 Jefferson, OH 45,947 39,999 22,884 17,115 15,238 24,761 Combined NO x Total 52,083 43,349 25,563 17,786 17,533 25,816

C. SO 2 Emissions Demonstrations
Table 11: Brooke County, WV SO 2 Emission Inventory Totals for 2005, 2008, 2015 and 2025 (tpy) Sector 2005 (Base) 2008 Attainment 2015 Interim 2015 Safety Margin 2025 Maintenance 2025 Safety Margin EGU 0 00 0 0 0 NonEGU 621 797 718 48 655 112 Area 168 164 157 7 146 17 LM 20 6 6 0 6 0 Nonroad 12 2 0 2 0 2 Onroad 7 22 1 1 1 TOTAL 828 941 883 58 809 132

Page 19 Weirton, WV 1997 PM 2.5 Redesignation and Maintenance PlanTable 12: Hancock County, WV SO 2 Emission Inventory Totals for 2005, 2008, 2015 and 2025 (tpy) Sector 2005 (Base) 2008 Attainment 2015 Interim 2015 Safety Margin 2025 Maintenance 2025 Safety Margin EGU 0 00 0 0 0 NonEGU 1,481 613 573 40 520 93 Area 729 249 237 11 221 27 LM 32 31 32 0 32 0 Nonroad 10 2 0 2 0 1 Onroad 7 21 1 1 1 TOTAL 2,258 897 843 54 774 123

Table 13: Jefferson County, OH SO 2 Emission Inventory Totals for 2005, 2008, 2015 and 2025 (tpy) Sector 2005 (Base) 2008 Attainment 2015 Interim 2015 Safety Margin 2025 Maintenance 2025 Safety Margin EGU 225,595 135,507 72,203 63,304 45,073 90,434 NonEGU 850 783 758 25 693 90 Area 111 109 102 2 92 19 MAR 26 22 13 9 0 21 Nonroad 17 3 0 3 0 3 Onroad 18 6 4 2 4 2 TOTAL 226,617 136,429 73,080 63,344 45,862 90,568

Page 20 Weirton, WV 1997 PM 2.5 Redesignation and Maintenance PlanTable 14: Weirton Nonattainment Area SO 2 Emission Inventory Totals for 2005, 2008, 2015 and 2025 (tpy) County 2005 (Base) 2008 Attainment 2015 Interim 2015 Safety Margin 2025 Maintenance 2025 Safety Margin Brooke, WV 828 941 883 58 809 132 Hancock, WV 2,258 897 843 54 774 123 WV SO 2 Total 3,086 1,838 1,726 111 1,583 254 Jefferson, OH 226,617 136,431 73,087 63,344 45,862 90,568 Combined SO 2 Total 229,703 138,268 74,813 63,455 47,446 90,823

D. Summary of PM 2.5 , NO x , and SO 2 Emission Reductions
Table 15: West Virginia Portion of the Weirton Area Comparison of 2008 attainment year and 2015 and 2025 projected emission estimates (tpy) 2008 Attainment 2015 Interim 2015 Projected Decrease 2025 Maintenance 2025 Projected Decrease PM 2.5 778 735 43 700 78 NO x 3,350 2,680 671 2,296 1,055 SO 2 1,838 1,726 111 1,583 254

Table 16: Ohio Portion of the Weirton Area Comparison of 2008 attainment year and 2015 and 2025 projected emission estimates (tpy) 2008 Attainment 2015 Interim 2015 Projected Decrease 2025 Maintenance 2025 Projected Decrease PM 2.5 2,036 2,005 30 1,998 38 NO x 39,999 22,884 17,115 15,238 24,761 SO 2 136,431 73,087 63,344 45,862 90,568

Page 21 Weirton, WV 1997 PM 2.5 Redesignation and Maintenance PlanTable 17: Weirton Area Comparison of 2008 attainment year and 2015 and 2025 projected emission estimates (tpy) 2008 Attainment 2015 Interim 2015 Projected Decrease 2025 Maintenance 2025 Projected Decrease PM 2.5 2,814 2,741 73 2,698 116 NO x 43,349 25,563 17,786 17,533 25,816 SO 2 138,268 74,813 63,455 47,446 90,823
As shown in the table above (Table 17), PM 2.5 emissions in the nonattainment area are projected to decrease by 73 tons in 2015 and 116 tons in 2025. NO x emissions in the nonattainment area are projected to decrease by 17,786 tons in 2015 and 25,816 tons in 2025. SO 2 emissions in the nonattainment area are projected to decline by 63,455 tons in 2015 and 47,446 tons in 2025.

The Weirton area shows a net reduction in PM 2.5 , NO x and SO 2 emissions, cleaner vehicles and fuels are expected to be in place in 2015 and 2025, and the CAIR Replacement Rule should be implemented by 2015 and these programs should cause an overall drop in all three pollutants emissions. Decreases from EPA rules covering Tier 2 Motor Vehicle Emissions Standards and Gasoline Sulfur Control Requirements [65FR 6698,10FEB2000], Highway Heavy-Duty Engine Rule [62FR54694, 21OCT1997], and the Non-Road Diesel Engine Rule [63FR56968, 23OCT1998] are factored into the changes.

E. Air Quality Improvement is Based on P ermanent and Enforceable Emission Reductions A demonstration that improvement in air quality be tween the year violations occurred and the year attainment was achieved is based on permanent and enforceable emission reductions and not on temporary adverse economic conditions or unusually favorable meteorology. Ambient air quality data from all monitoring s ites indicate that air quality met the NAAQS for PM 2.5 in 2007-2009 and in 2008-2010. EPA’s redesignation guidance (Policy Memo from John Calcagni, Director, Air Quality Management Di vision to Regional Air Directors: Air Procedures for Processing Requests to Redesignate Areas to Attainment ), dated September 4, 1992 (p. 9) states: “A state may generally demonstrate maintenance of the NAAQS by either showing that future emissions of a pollutant or its precursors will not exceed the leve l of the attainment inventory, or by modeling to show that the future mix of sources and emissi ons rates will not cause a violation of the NAAQS.”

Permanent and enforceable reductions of PM 2.5 , NO x , and SO 2 emissions have contributed to the attainment of the annual PM 2.5 standard. Some of these reductions were realized due to the application of tighter federal standards on highway heavy-duty engines (Control of Emissions of Air Pollution from Highway Heavy Duty Engines) and Nonroad diesel engines (Control of Emissions of Air Pollution from Nonroad Diesel Engines), the application of tighter federal standards on new vehicles (Control of Air Pollution from New Mo tor Vehicles: Tier 2 Motor Vehicle Emission
Page 22 Weirton, WV 1997 PM 2.5 Redesignation and Maintenance PlanStandards and Gasoline Sulfur Control Requirements), Title IV of the CAA, the NO x SIP Call, CAIR, CSAPR, and federal consent decrees requiring reductions of SO 2 and NO x emissions from utility sources. Reductions achieved are discussed in greater detail under Section V.
Table 18: Weirton Area Comparison of 2005 Base Year and 2008 Attainment Year Reductions by Sector 2005 2008 Decrease EGU NO x 41,047 35,487 5,560 EGU PM 2.5 1,308 1,373 (65)

EGU SO 2 225,595 135,507 90,088 Onroad NO x 3,129 2,530 599 Onroad PM 2.5 111 89 22

Onroad SO 2 32 10 22 Nonroad NO x 575 496 78 Nonroad PM 2.5 45 40 5

Nonroad SO 2 39 7 32

F. Emissions Tracking Provisions for future annual updates of the invent ory to enable tracking of the emission levels, including an annual emission statement from major sources. In West Virginia, major point sources in all coun ties are required to submit air emissions information annually. West Virginia DAQ prepares a new periodic inventory for all PM 2.5 precursor emission sectors every three years in accordance with EP A’s Air Emissions Reporti ng Requirements (AERR). These PM 2.5 precursor inventories will be prepared for fu ture years as necessary to comply with the inventory reporting requirements established in th e CFR. Emissions information will be compared to the 2005 base year and the 2025 projected maintena nce year inventories to assess emission trends, as necessary, and to assure continued compliance with the annual PM 2.5 standard.

Page 23 Weirton, WV 1997 PM 2.5 Redesignation and Maintenance PlanIV. TRANSPORTATION ANALYSIS

A. Onroad Emission Estimations The air quality analyses and underlying planning assumptions were developed by the Ohio Department of Transportation (ODOT), Division of Transportation System Development-Modeling and Forecasting Section and the Brooke-Hanco ck-Jefferson Metropolitan Planning Commission (BHJMPC or BHJ), in coordinati on with the Ohio Environmental Protection Agency (OEPA) and West Virginia Department of Environmental Prot ection (WVDEP). This evaluation represents the latest population and land use data available that calibrated the modeling process used to calculate the vehicle emissions for the mobile emissions budge ts as well as the input values for U.S. EPA's most recent emissions software (MOVES) for this attainment demonstration. The BHJ Region is comprised of the counties of Brooke and Hancock in the north panhandle of West Virginia and Jefferson in east-central Ohio. The BHJMPC serves as the Metropolitan Planning Organization (MPO). The MPO submitted the nece ssary Travel Demand Model networks along with all land use and social-economic demographics . The ODOT Modeling and Forecasting section performed the MOVES runs to generate travel de mand model based emission factors as well as the complete air quality analyses for the metropolitan area. Figure 5: Steubenville-Weirton, OH-WV non-attainment area

Page 24 Weirton, WV 1997 PM 2.5 Redesignation and Maintenance PlanB. Onroad Mobile Emissions Summary A Travel Demand Model (TDM) is the traditional fo recasting tool used to examine potential changes in future travel patterns for a specific study area, in this case the Brooke-Hancock-Jefferson Metropolitan Area. The BHJ MPO, with the assi stance of ODOT Modeling & Forecasting, maintains a validated region-wide TDM that employs a four-step modeling process consisting of trip generation, trip distribution, mode choice, and r oute assignment performed with the Cube Voyager software package. The model Outputs generate d from the TDM are link-by-link directional 24-hour traffic volumes for simulating Base Year and Horizon Year travel patterns generated by the LRTP transportation network.

The current BHJ TDM Validation Y ear is 2000. The model uses comparable Average Daily Traffic count data, updated social-economic variables fo r each of the analysis years by either updating existing or known land use commitment for 2008, 2009, and 2014, or projected 2014 and 2020 variables based on a straight-line extrapolation between 2009 set of variables and the Horizon Year 2030 variables. These networks represent all pla nned federal-aid projects as well as any regionally significant projects found in the BHJ TIP and LRTP e xpected to be open for tr affic by the end of each respective analysis year. The interagency consultati on process, as previously discussed, established the following model years for Brooke and Hancock counties, WV and Jefferson County, OH that reflected the most recent correspondence from the U.S. EPA: Analysis Year 2005 – Baseline Emissions Analysis Year 2008 – Attainment Year (Also maintenance plan base year) Analysis Year 2015 – Interim Year Analysis Year 2025 – Maintenance Plan End Year Identifying projected growth centers and unders tanding urban and rural population changes are essential to determine future transportation needs in a given study area. Critical elements include an understanding of the past and anticipated future shifts in the region’s economy, population, land use patterns, and other environmental factors over time. In turn, these factors are useful for predicting future transportation patterns and justify transportation improvements over the next twenty years.. Travel forecasting procedures require the user delineate the TDM study area into geographic areas called Traffic Analysis Zones (TAZ s). Typically, TAZs are based on factors such as land use, area types (urban, suburban or rural), or political government units such as cities, villages, or townships. TAZs represent centers of travel generators or a ttractors based on a set of demographic variables. The BHJ MPO collects and reviews the TDM independent variables that characterize current and future estimates of the metropolitan area’ social a nd economic activity that may influence land-use development patterns. In all, there are 376 TAZs in the BHJ model represented by 60 TAZs for Brooke County, 78 TAZs for Hancock County, and 237 TAZs for Jefferson County.

C. Emissions Model MOVES (Motor Vehicle Emissions Simulator) is a computer program designed by the EPA to estimate air pollution emissions from highway m obile sources. EPA published a Federal Register notice of availability [75 FR 9411] on March 2, 2010, to approve MOVES2010, hereafter referred to as MOVES. Upon publication of the Federal Register notice, MOVES became EPA’s approved motor vehicle emission factor model for use by state and local agencies to estimate VOCs, NO x , CO, Page 25 Weirton, WV 1997 PM 2.5 Redesignation and Maintenance PlanPM 10 and PM 2.5 and other pollutants and precursors from cars, trucks, motorcycles, and buses. MOVES replaces EPA’s previous emissions mode l, MOBILE6.2. MOVES can be used to estimate exhaust and evaporative emissions as well as brake and tire wear emissions from all types of on-road vehicles. An updated version of this software, MOVES2010a, was used for this analysis. MOVES2010a is a minor update to MOVES2010. MOVES2010a includes general performance improvements to MOVES2010, and also allows users to account for emissions under new car and light truck energy and greenhouse gas standards.

EPA believes that MOVES should be used in oz one, carbon monoxide, PM, a nd nitrogen dioxide SIP development as expeditiously as possible. The CAA requires that SIP inventories and control measures be based on the most current information and applicable models that are available when a SIP is developed. The MOVES model generated the emission factor f iles for base year-2005 and attainment year-2008 representing the transportation improvement progr ams implemented in the BHJ Region. The model also generated emission factors for two future year scenarios 2015 and 2025. Table 19 summarizes the settings used in the MOVES run specification file and the MOVES County-DataManager. D. Temperature and Relative Humidity Meteorological conditions, especially temperature and humidity, significantly affect on-road vehicle emissions. A series of Inter-Agency Consultation (IA C) conference calls were held during the winter of 2010/2011 which established two important conclusions, among others. First, this redesignation effort required the use of MOVES software for all mobile source emission analyses. And second, the annual emission estimates would be based upon a si ngle-season temperature/ humidity approach. The single season approach for temperature and relativ e humidity uses weather data collected by the National Oceanic and Atmospheric Administration (NOAA) National Climatic Data Center (NCDC). The data used in this report, taken from the Pittsburgh International Air port collection center, is representative of 12 months in 2009. Other factors which may significantly affect ve hicle emissions are roadway attributes, fleet characteristics and operational conditions. The appropriate inputs for such parameters were determined through the IAC process and are detailed in Appendix C.

Page 26 Weirton, WV 1997 PM 2.5 Redesignation and Maintenance PlanTable 19: MOVES Inputs RunSpec Parameter Settings MOVES Version 2010/08/26 Scale Custom Domain MOVES Modeling Technique Emission Factor Method Rates per Distance, Rates per Vehicle Time Span Time Aggregation: Hour 1 Month representing average annual temperatures All hours of day selected 16 speed bins, Weekdays only Geographic Bounds Brooke, Ha ncock, and Jefferson counties Vehicles/Equipment All source types, gasoline and diesel Road Type All road types including off-network Pollutants and Processes NO x , All PM 2.5 categories, SO 2 , Total Energy Consumption Strategies None General Output Units = grams, joules and miles

Output Emissions Time = hour, Location = custom area, on-road emission rates by road type and source use type.

County Data Manager Sources Source Type Population Combination of local and default data Local data (Ohio and West Virginia) from motor vehicle registration Default data used for source types 51, 52, 53, 61, and 62 Future year growth rate based on MPO model Household growth rate. Vehicle Type VMT Combination of local and default data HPMSVTypeYear VMT = daily VMT from travel demand model monthVMTFraction = default dayVMTFraction=default hourVMTFraction=local I/M Program None Fuel Formulation Default Fuel Supply Default Meteorology Data Local data obtained from NOAA National Climatic Data Center Data will consist of monthly high and low temperatures and daily relative humidity for 2002. Ramp Fraction Using the base year travel demand model for VHT fractions. Road Type Distribution Use ODOT and WV Division of Highways county summary VMT categorized by federal functional classes Age Distribution Combination of local and default data. Local data (Ohio and West Virginia) from motor vehicle registration Default data used for source types 41, 42, 43, 51, 52, 53, 61, and 62 The same age distribution will be used for all analysis years Average Speed Distribution Default Alternative Fuel Type Default

Page 27

Weirton, WV 1997 PM 2.5 Redesignation and Maintenance PlanE. Onroad Mobile Emission Estimations Tables 20 through 24 contain the results of the emissions analysis for the appropriate years. All emissions estimations are expressed in tons per year (tpy).
Table 20: Brooke County, WV Emissions Es timations for Onroad Mobile Sources 2005 2008 2015 2025 NO x (tpy) 540.40 412.02 174.71 62.47 PM 2.5 (tpy) 19.41 14.42 6.97 4.34 SO 2 (tpy) 7.01 2.11 1.51 1.26 Annual VMT 212,244,639 212,778,859 219,881,355 216,619,184

Table 21: Hancock County, WV Emissions Estimations for Onroad Mobile Sources 2005 2008 2015 2025 NO x (tpy) 482.75 360.25 149.00 52.09 PM 2.5 (tpy) 18.63 13.51 6.53 4.10 SO 2 (tpy) 6.58 1.92 1.36 1.10 Annual VMT 180,767,718 177,219,697 180,298,107 174,534,361

Table 22: Summary of West Virginia Emissions Estimations for Onroad Mobile Sources 2005 2008 2015 2025 NO x (tpy) 1,023.15 772.27 323.71 114.56 PM 2.5 (tpy) 38.04 27.93 13.50 8.44 SO 2 (tpy) 13.59 4.03 2.87 2.36 Annual VMT 393,012,357 389,998,556 400,179,462 391,153,545

Page 28 Weirton, WV 1997 PM 2.5 Redesignation and Maintenance PlanTable 23: Jefferson County, OH Emissions Estimations for Onroad Mobile Sources 2005 2008 2015 2025 NO x (tpy) 2,105.85 1,758.04 870.17 322.71 PM 2.5 (tpy) 73.17 60.97 31.88 16.49 SO 2 (tpy) 18.18 5.65 3.93 3.56 Annual VMT 562,071,084 557,286,295 544,597,475 572,657,778

Table 24: Emissions Estimate Totals for the Onroad Mobile Source Sector for the Steubenville-Weirton, OH-WV Area 2005 2008 2015 2025 NO x (tpy) 3,129.00 2,530.31 1,193.88 437.27 PM 2.5 (tpy) 111.22 88.89 45.37 24.93 SO 2 (tpy) 31.77 9.68 6.79 5.91 Annual VMT 955,083,441 947,284,851 944,776,937 963,811,323

Page 29 Weirton, WV 1997 PM 2.5 Redesignation and Maintenance PlanThe following table shows the emissions totals, by sector, for eachcounty in the nonattainment area. For a more detailed analysis seeAppendix C.Table 25: Percentage of Steubenville-Weirton, OH-WV Emissions Attributable to Mobile Sources in 2005, 2008, 2015 and 20252005 2008 2015 2025 2005 2008 2015 2025 2005 2008 2015 2025WeirtonBrookeCo.,WV Point‐EGU 0 0 0 0 0 0 0 0 0 0 0 0BrookeCo.,WV Point‐NonEGU 693 790 742 679 155 167 156 142 621 767 718 655BrookeCo.,WV Area 311 119 118 116 208 220 218 216 168 164 157 146BrookeCo.,WV LM 445 113 114 115 17 4 4 4 20 6 6 6BrookeCo.,WV NonRoad 205 169 88 59 11 9 6 4 12 2 0 0BrookeCo.,WV OnRoad540 412 175 62 19 14 7 4 7 2 2 1BrookeCo.,WV Subtotal 2,194 1,603 1,237 1,032 411 414 391 370 828 941 883 809HancockCo.,WV Point‐EGU 0 0 0 0 0 0 0 0 0 0 0 0HancockCo.,WV Point‐NonEGU 1,181 575 525 463 182 91 84 75 1,481 613 573 520HancockCo.,WV Area 1,447 158 157 155 314 233 230 230 729 249 237 221HancockCo.,WV LM 695 535 538 543 26 18 19 19 32 31 32 32HancockCo.,WV NonRoad 135 119 75 51 10 8 6 3 10 2 0 0HancockCo.,WV OnRoad483 360 149 52 19 14 7 4 7 2 1 1JeffersonCo.,OH Subtotal 3,942 1,747 1,443 1,264 550 364 345 331 2,258 897 843 774Total 6,136 3,350 2,680 2,296 961 778 735 700 3,086 1,838 1,726 1,58316.68% 23.05% 12.08% 4.99% 3.96% 3.59% 1.84% 1.21% 0.44% 0.22% 0.17% 0.15%SteubenvilleJeffersonCo.,OH Point‐EGU 41,047 35,487 19,488 12,632 1,308 1,373 1,405 1,450 225,595 135,507 72,20345,073JeffersonCo.,OH Point‐NonEGU 1,992 1,992 1,939 1,864 462 461 438 414 850 783 758693JeffersonCo.,OH Area 251 253 252 252 110 111 108 106 111 109 10292JeffersonCo.,OH MAR 317 301 203 71 8 7 5 1 26 22 130JeffersonCo.,OH NonRoad 234 208 131 97 24 23 17 11 17 3 00JeffersonCo.,OH OnRoad2,106 1,758 870 323 73 61 32 16 18 6 44JeffersonCo.,OH Subtotal 45,947 39,999 22,884 15,238 1,985 2,036 2,005 1,998 226,617 136,429 73,080 45,8624.58% 4.40% 3.80% 2.12% 3.69% 3.00% 1.59% 0.83% 0.01% 0.00% 0.01% 0.01%OnroadSubtotal 3,129 2,530 1,194 437 111 89 45 25 32 10 7 6Total 52,083 43,349 25,563 17,533 2,946 2,814 2,741 2,698 229,704 138,267 74,807 47,4466.01% 5.84% 4.67% 2.49% 3.77% 3.16% 1.66% 0.92% 0.01% 0.01% 0.01% 0.01%SO2Steubenville‐Weirton,OH‐WVNAAOnroadPercentageNAA County SectorWVPortionofNAAWVOnroadPercentageOHPortionOnroadPercentageSteubenville‐Weirton,OH‐WVNAASteubenville‐Weirton,OH‐WVNAANOx PM2.5Page 30Weirton, WV 1997 PM2.5Redesignation and Maintenance PlanOnroad mobile source SO 2 constitutes less than one tenth of one percent (<0.1%) of the area’s total SO 2 emissions in the 2015 and 2025 horizon years.

Onroad mobile source NO x constitutes less than five per cent(<5%) of the area’s total NO x emissions in the 2015 and 2025 horizon years.

Onroad mobile source PM 2.5 constitutes less than two percent (<2%) of the area’s total PM 2.5 emissions in the 2015 and 2025 horizon years. The federal Transportation Conformity rule allows pollutants/precursors to be exempt from conformity analysis under certain circumstances. 40CFR93.109(k) Areas with insignificant motor vehicle emissions. Notwithstanding the other paragraphs in this section, an area is not requi red to satisfy a regional emissions analysis for §93.118 and/or §93.119 for a given pollutant/pr ecursor and NAAQS, if EPA finds through the adequacy or approval process that a SIP demonstrates that regional motor vehicle emissions are an insignificant contributor to the air quality problem for that pollutant/precursor and NAAQS. The SIP would have to demonstrate that it would be unreasonable to expect that such an area would experience enough motor vehicle emissions growth in that pollutant/precursor for a NAAQS violation to occur. Such a finding would be based on a number of factors, including the per centage of motor vehicle emissions in the context of the total SIP inventory, the current state of air quality as determined by monitoring data for that NAAQS, the absence of SIP moto r vehicle control measures, and historical trends and future projections of the growth of motor vehicle emissions. . . [emphasis added] For the reasons outlined below, the DEP is here in making a finding that regional highway emissions of PM 2.5 , NO x and SO 2 are insignificant contributors to the nonattainment problem for the Weirton area. The finding will become final if EPA concurs and approves this SIP. First, the regional highway pollutant/precursor emi ssions constitute a relativ ely small fraction (<10%) of the overall emissions in all cas es, as shown in Table 25, above. Th erefore, DEP believes that the low contribution of both precursors and PM to the emissions inventory, in concert with the considerations detailed below, clearly warrants an insignificance finding with respect to transportation conformity. Another consideration is the significant emission decreases that are projected not only for the highway sector but also for the total emissions i nventory. As the charts below clearly demonstrate, all three pollutants decrease over the period of the maintenance plan and the percent contribution of highway emissions decrease as well.

Page 31 Weirton, WV 1997 PM 2.5 Redesignation and Maintenance PlanFigure 6: Steubenville-Weirton, OH-WV NAA NO x Emissions by Sector

Figure 7: Steubenville-Weirton, OH-WV NAA PM 2.5 Emissions by Sector

Page 32 Weirton, WV 1997 PM 2.5 Redesignation and Maintenance PlanFigure 8: Steubenville-Weirton, OH-WV NAA SO 2 Emissions by Sector

Second, the current air quality (CY 2011) is represented by a design value of 13.0 ug/m 3 . This value is significantly lower than the 17.0 ug/m 3 design value (2002-2004) upon which the nonattainment designation was based, and is comfortably below the NAAQS. Figure 2 on page 6 shows the general improvement of PM 2.5 concentrations from the year 2001 to date. The design values dropped from 17.4 μ g/m 3 (2001-03) to 17.0 (2002-04) to 16.8 (2003-05) and reached a plateau of 16.4 for two consecutive periods (2004-06 & 2005-07). The concen trations continued to drop to 15.4 (2006-08) to 14.4 (2007-09) to 13.7 (2008-09). This air quality im provement may be attributed to an overall decrease in sulfates from SO 2 reductions mandated by the Acid Rain Program, and preliminary implementation of controls to meet CAIR and is expected to continue under the CAIR replacement rule, CSAPR. Overall, the PM concentrations ha ve improved since the beginning of the decade, as shown in Figure 2. EPAhas determined, as of September 14, 2011, that based on 2007 to 2009 ambient air quality data, the Steubenville-Weirt on nonattainment area has attained the 1997 annual PM 2.5 NAAQS. This determination, in accordance with 40 CFR 52.1004(c) [76 Federal Register 56643]. The area is designated as attainment for all other criteria pollutants. Given the relatively small contribution of the highw ay emissions to the total SIP inventory, highway emissions are not likely to contribute significantly to the local PM 2.5 mass concentrations. Among other factors, this is largely due to the dominance of sulfates in the overall PM mass, coupled with the very low contribution of highway sources to those sulfate totals. Third, historically there have been no West Virg inia SIP requirements for motor vehicle control measures. The Weirton area is subject to Trans portation Conformity for the 8-hour ozone standard, with SIP-approved, seasonal budgets for NO x and Volatile Organic Compounds (VOC). Further, the entire nonattainment area is currently subject to Transportation Conformity for the PM 2.5 standard. Page 33 Weirton, WV 1997 PM 2.5 Redesignation and Maintenance PlanEmissions analysis has been mandatory for a nnual highway emissions of direct PM and NO x . However, upon a positive adequacy review or appr oval of this SIP submittal, no highway emissions analysis will be required under the annual PM 2.5 standard. Highway analysis of seasonal ozone precursors would continue to be mandatory. And, PM 2.5 hot-spot analyses woul d continue to apply for required projects under 40CFR93.116 and 93.123(b) of the Transportation Conformity Rule. Fourth, BHJ has extensively researched the area local historical trends and growth patterns to develop the LRTP/TIP and support transportation conform ity evaluations. There is no reason to expect highway motor vehicle emissions gr owth that would lead to a PM 2.5 NAAQS violation. BHJ and ODOT have estimated emissions out, at least, to the calendar year 2035 c onfirming this, based on federally approved conformity determinations. The conformity analysis for the Weirton area took into account all the regional capacity projects, which are scheduled for implementation through the transportation plan horizon year and the four year TIP. The air quality analysis contained in the report was the basis for the most recent federally approved conformity determination. The PM conformity tests were performed for calendar years 2008, 2014, 2018, 2025 and 2035. For each of those years, vehi cle miles traveled (VMT) and Speed were developed by the Federal Functional Class codes, wh ich are derived from the regional traffic model assignments that are made for each of those years. Pursuant to the Transportation Conformity interim tests, NO x and direct PM were evaluated. The anal ysis employed the MOBILE6.2 emissions factor model. West Virginia (Brooke & Hancock Countie s) NOx emissions decrease dramatically from 787.5 tons/year [2008] to 414.0 t py [2014] to 306.8 tpy [2018] to 195.9 tpy [2025]. The decrease continues to the last value to to 176.6 [2035], which is less than one-fourth of the 2008 level. Direct PM dropped from 13.8 to 5.78 tpy [2035] . DEP believes this result solidly demonstrates that highway emissions will remain insignificant in the future. Figure 9: Onroad NO x Emissions Tons per Year

Page 34 Weirton, WV 1997 PM 2.5 Redesignation and Maintenance PlanV. CONTROL MEASURES AND REGULATIONS CAA Section107 (d)(3)(E)(ii), 107(d)(3)(iv), and 107(d)(3)(E)(v) A. Reasonably Available Control Measures (RACM) and Reasonably Available Control Technology (RACT) Section 172(c)(1) of the 1990 Clean Air Act Amendm ents (CAA) requires states with nonattainment areas to implement reasonably available control m easures (RACM) and reasonably available control technology (RACT). States with nonattainment areas must submit a SIP providing for implementation of all reasonably available control measures as expeditiously as practicable (including such reductions in emissions from existing sources in the area as may be obtained through the adoption, at a minimum, of reasonable available control technology). EPA states on their website regarding RACM, RACT, and the Clean Data Policy [ www.epa.gov/airquality/urbanair/sipstatus/policy_details.html ]: Under EPA’s Clean Data Policy and the regulations that embody it, 40 CFR 51.918 (1997 8-hour ozone) and 51.1004(c) (PM-2.5), an EPA ru lemaking determination that an area is attaining the relevant standard suspends th e area’s obligations to submit an attainment demonstration, reasonable available control m easures (RACM), reasonable further progress, contingency measures and other planning require ments related to attainment for as long as the area continues to attain. EPA’s statutor y interpretation of the Clean Data Policy is described in the “Final Rule to Implemen t the 8-hour Ozone National Ambient Air Quality Standard—Phase 2" (Phase 2 Final Ru le). 70 FR 71612, 71644-46 (Nov. 29, 2005) (ozone); See also 72 FR 20585, 20665 (Apr. 25, 2007) (PM-2.5). EPA believes that the legal bases set forth in detail in our Phase 2 Final rule, our May 10, 1995 memorandum from John S. Seitz, entitled “Reasonable Further Progress, Attainment Demonstration, and Related Requirements for Ozone Nonattainment Areas Meeting the Ozone National Ambient Air Quality Standard,” and our December 14, 2004 memorandum from Ste phen D. Page entitled “Clean Data Policy for the Fine Particle National Ambient Air Quality Standards” are equally pertinent to all NAAQS. EPA has codified the Clean Data Po licy for 1997 8-hour ozone and PM-2.5, and has also applied it in individual rulemakings for 1-hour ozone and PM-10. Under the Clean Data Policy, EPA may issue a determination of attainment (known informally as a Clean Data Determination) after notice and comment rulemaking determining that a specific area is attaining the relevant st andard. For such areas the requirement to submit to EPA those SIP elements related to attain ing the NAAQS is suspended for so long as the area continues to attain the standard. These planning elements include reasonable further progress (RFP) requirements, attainment demonstrations, RACM, contingency measures, and other state planning requirements related to attainment of the NAAQS. The determination of attainment is not equivalent to a redesignati on, and the state must still meet the statutory requirements for redesignation in order to be redesignated to attainment. A determination of attainment for purposes of th e Clean Data Policy/regulations is also not linked to any particular attainment deadline, and is not necessarily equivalent to a determination that an area has attained the standard by its applicable attainment deadline, e.g., under section 181(b).

Page 35 Weirton, WV 1997 PM 2.5 Redesignation and Maintenance PlanOn September 14, 2011, in accordance with Section 179(c)(1) of the CAA, EPA determined that the Steubenville-Weirton, OH-WV PM 2.5 nonattainment area had attained the 1997 annual PM 2.5 NAAQS, this determination [76 FR 56641] was base d upon three years of complete, quality assured, quality-controlled data for the 2007-2009, as well as the 2008-2010 data. EPA further determined that, in accordance with the PM 2.5 Implementation Rule of April 5, 2007 [72FR20664], the Steubenville-Weirton, OH-WV area had attained the 1997 annual PM 2.5 NAAQS by the applicable attainment date of April 5, 2010. Complete quality-assured PM 2.5 ambient air quality data for the most recent three (3) years, 2008 through 2010,and pre liminary data for 2009 through 2011, demonstrate that the air quality continues to meet the NAAQS for annual PM 2.5 in this nonattainment area. Therefore, RACM, including RACT, no longer applies. B. Inventory of Actual Emissions Section 172(c)(3) requires states to submit a comprehe nsive inventory of actual emissions in the area, including the requirement for periodic revisions as determined necessary. 40 CFR 51.1008 requires such inventory to be submitted within three y ears of designation and requires a baseline emission inventory for calendar year 2002 or other suitable year to be used for attainment planning. In accordance with the Consolidated Emissions Reporting Rule (CERR), West Virginia 2002 and 2005 statewide comprehensive emissions inventories were submitted to EPA’s CDX site on April 29, 2005 and June 1, 2007, respectively. The West Virg inia 2008 comprehensive emissions inventory was submitted to the CDX on May 30, 2010 consistent with the requirements of the Air Emissions Reporting Requirements (AERR). We are here by resubmitting the 2005, and 2008 comprehensive inventories for the Weirton nonattainment area. West Virginia will continue to provide updates to future inventories in accordance with EPA’s AERR rule. As discussed in Section III.F, West Virginia DAQ submits, and commits to submit, emission inventories every three years. C. Evidence that control measures required in past PM 2.5 SIP revisions have been fully implemented.

1. NO x SIP Call, CAIR and CSAPR The EPA NO x SIP Call required 22 states to pass rules that would result in significant emission reductions from large EGUs, industrial boilers, and cement kilns in the eastern United States. West Virginia passed this rule in 2002. NO x SIP Call requirements are incorporated into permits along with monitoring, recordkeeping, and reporting necessary to ensure ongoing compliance. West Virginia DAQ also has an active enforcemen t program to address violations discovered by field office staff. Compliance is tracked thr ough the Clean Air Markets data monitoring program. In West Virginia, this rule accounted for a reduction from 2003 levels of approximately 57 percent of NO x emissions by 2008 from sources subject to the rule. The other 21 states also adopted these rules. On March 10, 2004, the EPA promulgated the CA IR. Beginning in 2009, EPA’s CAIR rule required EGUs in 28 eastern states and the Distri ct of Columbia to significantly reduce emissions of NO x and SO 2 . CAIR replaced the NO x SIP Call for EGUs. National NO x emissions were expected to be cut from 4.5 million tons in 2004, to a cap of 1.5 million tons by 2009, and 1.3 Page 36 Weirton, WV 1997 PM 2.5 Redesignation and Maintenance Planmillion tons in 2018 in 28 states. States were require d to submit a CAIR SIP as part of this effort. West Virginia submitted an initial CAIR SI P on June 1, 2006. Subsequently, WV submitted an abbreviated CAIR SIP on June 8, 2007, which requested authority to allocate CAIR allowances. Final revisions to the CAIR SIP were subm itted on April 22, 2008. The revised CAIR SIP was approved in a direct final action on August 2, 2009 (74FR38536 ). On July 6, 2010, EPA proposed a replacement to th e CAIR program, the Transport Rule [75 FR 45210]. On July 6, 2011, EP A finalized the Transport Rule, now commonly referred to as the Cross-State Air Pollution Rule (CSAPR) [ 76FR48208, 08AUG2011] in time for reductions to begin in 2012. As finalized, the CSAPR would have preserved the initial reductions achieved under CAIR and provided more reductions in NO x and SO 2 emissions in 2012 and 2014, ahead of the 2015 CAIR Phase 2.

EPA states on their Cross-State Air Pollution Ru le homepage: “By 2014, power plants in states common to both the Cross-State Air Pollution Rule and CAIR will achieve annual SO 2 emissions around 1.8 million tons lower and annual NO x emissions around 76,000 tons lower than what would have been achieved at that time under CAIR.” ( www.epa.gov/airtransport/basic.html )

Controls for EGUs under the NO x SIP Call formally commenced May 31, 2004. Emissions covered by this program have been generally trending downward since 1998 with larger reductions occurring in 2002 and 2003. Data taken from the EPA Clean Air Markets web site, quantify the gradual NOx reductions that have occurred in West Virginia as a result of Title IV of the 1990 CAA Amendments and the beginning of the NO x SIP Call Rule. West Virginia developed the NO x Budget Trading Program rules in 45CSR 1 and 26 in response to the SIP Call. 45CSR1 regulated EGUs and 45CSR26 regulated certain non-EGUs under a cap and trade program based on an 77 percent reduction of NO x emissions from EGUs and a 60 percent reduction of NO x emissions from non-EGUs, compared to hist orical levels. This cap was in place through 2008, at which time the CAIR program superseded it as discussed above. Section III above discussed the reductions West Virginia has seen as a result of CAIR. On April 21, 2004, EPA published Phase II of the NO x SIP Call that established a budget for large (greater than 1 ton per day emissions) stationary internal combustion engines. 45CSR1 addresses stationary internal combustion engines, all used in natural gas pipeline transmission. EPA approved this revision to the SIP on November 27, 2006. An 82 percent NO x reduction from 1995 levels was anticipated. Approval of the comp liance plans occurred by August 4, 2006, and March 1, 2007 and the compliance demonstration began May 1, 2007.

2. Tier II Emission Standards for Vehicles and Gasoline Sulfur Standards [65FR6698, 10FEB2000] In February 2000, EPA published a federal rule to significantly reduce emissions from cars and light trucks, including sport utility vehicles (S UVs). Under this proposal, automakers will be required to sell cleaner cars, and refineries will be required to make cleaner, lower sulfur gasoline. This rule applies nationwide. The federal rules phased in between 2004 and 2009. EPA estimated that NO x emission reductions will be approximately 77 percent for passenger cars, 86 percent for smaller SUVs, light trucks, and minivans, and 65 to 95 percent reductions for larger SUVs, vans, and heavier trucks. The sulfur content of gasoline is estimated to be reduced by up to 90 percent. VOC emission reductions will be approximately 12 percent for passenger Page 37 Weirton, WV 1997 PM 2.5 Redesignation and Maintenance Plancars, 18 percent for smaller SUVs, light trucks, and minivans, and 15 percent for larger SUVs, vans, and heavier trucks. 3. Heavy-Duty Diesel Engines [65FR59896, 06OCT2000] In October 2000, EPA published a final rule for Hi ghway Heavy Duty Engines, a program which includes low-sulfur diesel fuel standards, which were phased in from 2004 through 2007. This rule applies to heavy-duty gasoline and diesel truc ks and buses. This rule resulted in a 40 percent reduction in NO x from diesel trucks and buses, a large sector of the mobile sources NO x inventory. It also estimated the level of sulfur in highway diesel fuel would be reduced by 97 percent by mid-2006.

4. Clean Air Non-road Diesel Rule [69FR38958, 29JUN2004] In June 2004, EPA published the Clean Air Non-road Diesel Rule. This rule applies to diesel engines used in industries such as construction, ag riculture, and mining. It also contains a cleaner fuel standard similar to the highway diesel pr ogram. The new standards will cut emissions from non-road diesel engines by more than 90 percent. Non-road diesel equipment, as described in this rule, currently accounts for 47 percent of diesel particulate matter (PM) and 25 percent of NO x from mobile sources nationwide. Sulfur levels will be reduced in non-road diesel fuel by 99 percent from 2004 levels, from approximately 3,000 parts per million (ppm) to 15 ppm in 2009. New engine standards took effect, based on engi ne horsepower, starting in 2008. Together, these rules will substantially reduce local and regional sources of PM 2.5 precursors. D. Assurance that existing control measures will remain in effect West Virginia commits to maintaining the afor ementioned control measures after redesignation. West Virginia hereby commits that any changes to its rules or emission limits applicable to PM 2.5 , SO 2 , and NO x as required for maintenance of the annual PM 2.5 standard in the Weirton area, will be submitted to EPA for approval as a SIP revision. West Virginia, through the Division of Environmen tal Protection, DAQ, has the legal authority and necessary resources to actively enforce any viol ations of its rules or permit provisions. After redesignation, it intends to continue enforcing all rules that relate to the emission of PM 2.5 precursors in the Weirton Area.

Page 38 Weirton, WV 1997 PM 2.5 Redesignation and Maintenance PlanVI. SUPPLEMENTAL MODELING ANALYSES Although EPA’s Redesignation Guidance does not re quire modeling nonattainment areas seeking redesignation, extensive modeling has been pe rformed covering the Steubenville-Weirton, OH-WV area to determine the effect of national emission control strategies on PM 2.5 concentrations. These modeling analyses determined that the Steube nville-Weirton, OH-WV area is significantly impacted by regional transport of PM 2.5 and its precursors, and that regional SO 2 and NO x reductions are an effective way to attain the annual standards for PM 2.5 in this area. Future year modeled annual PM 2.5 concentrations are expected to be reduced by 6% to 31% from baseline design values. Examples of these modeling analyses are described below. A. EPA Modeling for the Cross State Air Pollution Rule (Final Transport Rule) EPA performed modeling to support the emission reduc tions associated with the Final Transport Rule or the Cross State Air Pollution Ru le (CSAPR), as it is currently called. EPA used the Comprehensive Air Quality Model with Extension (CAMx) versi on 5.3 applied to the 2005 meteorology as processed by the Mesoscale Model (MM5), Version 3.7.4. Em issions input into the CAMx included SO 2 , NO x , VOC, NH 3 and direct PM 2.5 for 2005. The modeling was based on the annual fine particle design values calculated from 2003 through 2005, 2004 through 2006, and 2005 through 2007. Future year modeling was conducted, and the future year design values for 2012 and 2014 were evaluated for attainment of the annual NAAQS for PM 2.5 of 15 μg/m 3 , as shown in Table 26. The Brooke County monitors (54-019-0005, 54-009-0011) and the Hancoc k County monitor (54-029-1004) represent the Weirton area. As indicated in the Air Quality Modeling Techni cal Support Document (TSD) for the CSAPR, air quality modeling was performed for several emissions cases: a 2005 base year, a 2012 “no CAIR” base case, a 2014 “no CAIR” base case, and the 2014 remedy case. Modeling results for the Weirton area (Brooke County monitor, 54-009-0005) show a 2.19 μg/m 3 (13.3%) decrease in the average PM 2.5 concentration for 2012 and a 2.68 μg/m 3 (16.2%) decrease in the average concentration for 2014, without accoun ting for CAIR or reductions required by the Transport Rule or CSAPR. A reduction of 5.18 μg/m 3 (31.4%) from the 2003-2007 baseline is expected for 2014 with the implementation of the CSAP R. It should also be noted that the base year design value used by EPA in their modeling wa s taken from 2003 through 2007 and is higher than the current 2009 through 2011 design value of 13.0 μg/m 3 in the area. Furthermore, the monitored design values for 2008-2010 a nd 2009-2011 of 13.7 and 13.0 μg/m 3 , respectively, are less than the modeled base case design vales for 2012 and 2014. Figures 2 and 3 (in Section II) show the downward trend of the design valu es from 1999 through 2010 for the PM 2.5 monitors in West Virginia and Ohio.

Page 39 Weirton, WV 1997 PM 2.5 Redesignation and Maintenance PlanTable 26: CSAPR Annual PM2.5Design Values (μg/m3)Site ID County 2003-2007AverageAmbientValue2003-2007MaximumAmbientValues2012 BaseCaseAverageValues2012 BaseCaseMaximumValues2014 BaseCaseAverageValues2014 BaseCaseMaximumValues2014RemedyAverageValues2014RemedyMaximumValues54-003-0003 Berkeley 15.93 16.19 14.09 14.32 13.70 13.92 11.81 11.9954-009-0005 Brooke 16.52 16.80 14.3314.58 13.84 14.09 11.34 11.5554-009-0011 Brooke 16.04 16.37 13.8714.15 13.39 13.66 10.89 11.1354-011-0006 Cabell 16.30 16.57 14.71 14.94 14.05 14.28 11.57 11.7554-029-1004 Hancock 15.76 16.64 13.73 14.51 13.28 14.03 10.81 11.4454-033-0003 Harrison 13.99 14.19 13.17 13.36 12.71 12.90 9.36 9.4954-039-0010 Kanawha 15.15 15.38 13.40 13.60 12.78 12.97 10.13 10.2854-039-0011 Kanawha 13.17 13.17 11.67 11.67 11.13 11.13 8.67 8.6754-039-1005 Kanawha 16.52 16.59 14.65 14.71 14.01 14.06 11.30 11.3554-049-0006 Marion 15.03 15.25 14.22 14.43 13.76 13.95 10.16 10.3054-051-1002 Marshall 15.19 15.33 13.25 13.38 12.75 12.87 10.07 10.1754-061-0003 Monongalia 14.35 14.47 12.89 13.01 12.41 12.53 9.28 9.4054-069-0010 Ohio 14.58 14.58 12.5312.53 12.05 12.05 9.51 9.5154-081-0002 Raleigh 12.90 13.03 11.22 11.33 10.70 10.80 8.39 8.4754-107-1002 Wood 15.40 15.44 13.7413.77 13.16 13.20 10.84 10.87Source: Air Quality Modeling Final Technical Support Document for the Final Cross-State Air Pollution Rule , pages B-61 - B-62.(www.epa.gov/airtransport/techinfo.html)Page 40Weirton, WV 1997 PM2.5Redesignation and Maintenance PlanB. EPA Modeling for Proposed Transport Rule 2010 EPA performed modeling to support the emission reduc tions associated with the Proposed Transport Rule. EPA used the Comprehensive Air Quality M odel with Extension (CAMx Version 5), applied to the 2005 meteorology as processed by the Mesoscale Model (MM5), Version 3.7.4. Emissions input into the CAMx included SO 2 , NO x , VOC, NH 3 and direct PM 2.5 for 2005. The modeling was based on the annual fine particle design va lues calculated from 2003 through 2005, 2004 through 2006, and 2005 through 2007. Future year modeling was conducted, and the future year design values for 2012 and 2014 were evaluated for attainment of the annual NAAQS for PM 2.5 of 15 μg/m 3 , as shown in Table 27. The Brooke County monitors (54-009-0005, 54-009-0011) and the Hancock County monitor (54-029-1004) represent the Weirton area.
Table 27: Proposed Transport Rule Modeling Results from EPA - 2010 Monitor ID County Design Value 2003-2007

(μg/m 3 ) Future Design Value

2012 Base

(μg/m 3 ) Future Design Value

2014 Base

(μg/m 3 ) Future Design Value 2014 Remedy (μg/m 3 ) 54-003-0003 Berkeley 15.93 14.95 14.64 12.44 54-009-0005 Brooke 16.52 14.95 14.51 12.02 54-009-0011 Brooke 16.04 14.49 14.05 11.56 54-011-0006 Cabell 16.30 15.25 14.65 12.09 54-029-1004 Hancock 15.76 14.34 13.93 11.48 54-033-0003 Harrison 13.99 13.82 13.30 9.94 54-039-0010 Kanawha 15.15 14.01 13.45 10.77 54-039-0011 Kanawha 13.17 12.23 11.74 9.24 54-039-1005 Kanawha 16.52 15.28 14.69 11.97 54-049-0006 Marion 15.03 14.96 14.41 10.79 54-051-1002 Marshall 15.19 13.96 13.44 10.74 54-061-1003 Monongalia 14.35 13.72 13.14 10.01 54-069-0010 Ohio 14.58 13.18 12.72 10.15 54-081-0002 Raleigh 12.90 11.88 11.40 9.01 54-107-1002 Wood 15.40 14.31 13.77 11.40 Source: Technical Support Document for the Proposed Transport Rule, pages B-52 - B-53. ( www.epa.gov/airquality/transport/pdfs/TR_AQModeling_TSD.pdf ) EPA stated in the preamble to the proposed Transport Rule that the “baseline analysis takes into account emissions reductions associated with the im plementation of all federal rules promulgated by December 2008 and assumes that CAIR is not in effect.” [75FR 45233, 02AUG2010] Page 41 Weirton, WV 1997 PM 2.5 Redesignation and Maintenance PlanModeling results for the Weirton area (Brooke County monitor, 54-009-0005) show a 0.98 μg/m 3 (5.9%) decrease in the PM 2.5 concentration for 2012 and a 1.29 μg/m 3 (7.8%) decrease in the concentration for 2014, without accounting for CAIR or reductions required by the Transport Rule. A reduction of 3.49 μg/m 3 (21.1%) from the 2003-2007 baseline is expected for 2014 with the implementation of the Transport Rule. It should also be noted that the base year design value used by EPA in their modeling was taken from 2003 through 2007 and is higher than the current 2009 through 2011 design value of 13.0 μg/m 3 in the area. Furthermore, the monitored design values for 2007-2009, 2008-2010 and 2009-2011 of 14.4, 13.7 and 13.0 μg/m 3 , respectively, are less than the modeled base case design vales for 2012 and 2014. Figures 2 and 3 (in Section II) show the downward trend of the design valu es from 1999 through 2010 for the PM 2.5 monitors in West Virginia and Ohio.

C. VISTAS/ASIP Emissions and Air Quality Modeling to Support PM 2.5 and 8-hour Ozone State Implementation Plans VISTAS/ASIP conducted modeling to determine the impact of CAIR and other control programs in the southeast, including West Virginia. The VISTAS/ASIP modeling used Version 4.51 of the Community Multi-scale Air Quality (CMAQ) modeling system with enhanced secondary organic aerosol (SOA) module (SOAmods) applied to the year 2002 meteorology, as processed by MM5. Emissions input into CMAQ included SO 2 , NO x , VOC, NH 3 and direct PM 2.5 for 2002. The modeling was based on 2000 through 2004 design values. Fu ture year modeling for 2009, 2012 and 2018 was conducted and the future year design values were determined with the emission reductions associated with CAIR, as shown in Table 28. The Transport Ru le is expected to provide reductions above and beyond CAIR. The Brooke County monitors ( 54-009-0005, 54-009-0011) and the Hancock County monitor (54-029-1004) represent the Weirton ar ea. The Brooke County monitor 54-009-0011 was originally thought to be located in Hancock County, with the ID number 54-029-0011, but was determined to actually be located in Brooke county. The monitor remains in the same location. The VISTAS/ASIP modeling results for the We irton area (Brooke County monitor, 54-009-0005) predicted a 2.7 μg/m 3 (16.7%) decrease in the projected PM 2.5 concentration for 2009 from the 2002 design value. As shown in Table 1, the actua l monitored design value for 2007-2009 was 14.4 μg/m 3 , a 1.8 μg/m 3 (11.1%) improvement, slightly less than predicted. The modeling results show a continued improvement in the area, with a PM 2.5 concentration of 12.3 μg/m 3 by 2018, a 24.1% reduction from the 2002 design value. The current 2009-2011 design value for the area is 13.0 μg/m 3

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Page 42 Weirton, WV 1997 PM 2.5 Redesignation and Maintenance PlanTable 28: VISTAS/ASIP 2009, 2012 and 2018 Modeling Results (with CAIR) Monitor ID County 2002 Annual DVC Annual DVF 2009 2012 2018 54-003-0003 Berkeley 16.2 13.5 12.9 12.3 54-009-0005 Brooke 16.7 13.6 13.3 12.6 54-011-0006 Cabell 16.5 14.4 13.7 13.3 54-029-0011 Hancock 16.0 13.0 12.6 11.9 54-026-1004 Hancock 17.3 14.0 13.7 13.0 54-033-0003 Harrison 14.0 11.6 10.7 10.4 54-039-0010 Kanawha 15.4 13.1 12.2 11.7 54-039-1005 Kanawha 17.1 14.7 13.7 13.2 54-049-0006 Marion 15.3 12.9 12.0 11.6 54-051-1002 Marshall 15.6 13.2 12.7 12.1 54-055-0002 Mercer 12.7 10.6 9.7 9.1 54-061-0003 Monongalia 14.8 12.3 11.5 11.0 54-069-0008 Ohio 15.1 12.6 12.1 11.5 54-081-0002 Raleigh 13.1 11.0 10.1 9.5 54-089-0001 Summers 10.1 8.3 7.6 7.1 54-107-1002 Wood 16.1 13.8 13.4 12.6 Source: Technical Support Document for the Association for S outheastern Integrated Planning (ASIP) Emissions and Air Quality Modeling to Support PM 2.5 and 8-Hour Ozone State Implementation Plans, March 24, 2008.

Page 43 Weirton, WV 1997 PM 2.5 Redesignation and Maintenance PlanD. EPA’s CAIR Modeling One air quality modeling exercise that contains results for West Virginia’s nonattainment areas is the EPA’s modeling for the CAIR. The Technical Support Document for the CAIR, March 2005, provides modeling results with and without the im plementation of the CAIR. Differences between the EPA’s modeling and VISTAS modeling are: • The meteorology was for 2001, • The DVB was the weighted design values for the 1999-2003 period, and • The modeling results were for 2010. The DVF was calculated using the CAIR SMAT tool . The CAIR modeling results are listed in Table 29.
Table 29: EPA CAIR Modeling Results State County Average 99-03 2010 Base 2010 CAIR 2015 Base 2015 CAIR WV Berkeley 16.18 15.69 13.43 15.32 12.73 WV Brooke 16.96 16.63 14.42 16.51 14.05 WV Cabell 17.22 17.03 15.08 16.86 14.64 WV Hancock 17.40 17.06 14.89 16.97 14.54 WV Harrison 14.40 14.15 11.90 13.82 11.31 WV Kanawha 17.75 17.56 15.27 17.17 14.66 WV Marion 15.58 15.32 12.90 14.98 12.23 WV Marshall 16.07 15.81 13.46 15.52 12.87 WV Mercer 12.97 12.52 10.82 12.14 10.16 WV Monongalia 14.96 14.77 12.31 14.37 11.40 WV Ohio 15.37 15.14 12.81 14.84 12.22 WV Raleigh 13.54 13.19 11.33 12.80 10.66 WV Summers 10.46 10.21 8.63 9.89 8.07 WV Wood 16.88 16.66 14.14 16.69 13.88

Page 44 Weirton, WV 1997 PM 2.5 Redesignation and Maintenance PlanThe EPA’s results were for the highest monitor in a county where more than one monitor is located. The EPA’s modeling results predicted that the Weirton (Brooke and Hancock Counties) nonattainment area would be below the annual PM 2.5 standard by 2010. Although this was one year later than the attainment year for the area, the EPA’s predicted 2010 CAIR DVF was 0.3 μg/m 3 less than the DAQ monitored 3 year design value for 2010 of 13.7 μg/m 3 . The modeling still supports that the area will continue to attain the annual PM 2.5 standard through 2015 with a projected design value of 14.05 μg/m 3 , which is 1.05 μg/m 3 (8.1%) higher than the current 2009-2011 design value for the area of 13.0 μg/m 3

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Page 45 Weirton, WV 1997 PM 2.5 Redesignation and Maintenance PlanVII. CONTINGENCY MEASURES CAA Section 107(d)(3)(E)(v)

A. Maintenance Plan Review West Virginia hereby commits to review its ma intenance plan eight years after redesignation, as required by Section 175(A) of the CAA.

B. Corrective Actions West Virginia hereby commits to adopt and expeditiously implement necessary corrective actions in the following circumstances: 1. Warning Level Response A warning level response shall be prompted whenever the PM 2.5 average of the weighted annual mean of 15.5 μg/m 3 occurs in a single calendar year within the maintenance area. A warning level response will consist of a study to determine whether the PM 2.5 value indicates a trend toward higher PM 2.5 values or whether emissions appear to be increasing. The study will evaluate whether the trend, if any, is likely to continue and, if so, the control measures necessary to reverse the trend taking into consideration ease and tim ing for implementation as well as economic and social considerations. Implementation of necessary controls in response to a warning level response trigger will take place as expeditiously as possible, but in no event later than 12 months from the conclusion of the most recent calendar year. Should it be determined through the warning level study that action is necessary to reverse the noted trend, the procedures for control selec tion and implementation outlined under “action level response” shall be followed. 2. Action Level Response An action level response shall be prompted whenev er a two-year average of the weighted annual means of 15.0 μg/m 3 or greater occurs within the maintena nce area. A violation of the standard (three-year average of the we ighted annual means of 15.0 μg/m 3 or greater) shall also prompt an action level response. In the event that the action level is triggered and is not found to be due to an exceptional event, malfunction, or noncompliance with a permit condition or rule requirement, West Virginia DAQ in conjunction with the metropolitan planning organization or regional council of governments, will determine additional control measures needed to assure future attainment of the 1997 PM 2.5 NAAQS. In this case, measures that can be implemented in a short time will be selected in order to be in place within 18 months fr om the close of the calendar year that prompted the action level. West Virginia DAQ will also consider the timing of an action level trigger and determine if additional, signifi cant new regulations not currently included as part of the maintenance provisions will be implemented in a timely manner and will constitute our response.

Page 46 Weirton, WV 1997 PM 2.5 Redesignation and Maintenance Plan3. Control Measure Selection and Implementation Adoption of any additional control measures is s ubject to the necessary administrative and legal process. This process will include publication of notices, an opportunity for public hearing, and other measures required by West Virginia law for rulemaking. If a new measure/control is already promulgated and scheduled to be implemented at the federal or State level, and that measure/control is determ ined to be sufficient to address the upward trend in air quality, additional local measures may be unnecessary. Furthermore, West Virginia DAQ will submit to EPA an analysis to demonstrate th e proposed measures are adequate to return the area to attainment. C. Potential Contingency Measures Contingency measures to be considered will be selected from a comprehensive list of measures deemed appropriate and effective at the time the se lection is made. The se lection of measures will be based on cost-effectiveness, emission reduction potential, economic and social considerations or other factors that West Virginia DAQ deems appr opriate. West Virginia DAQ will solicit input from all interested and affected persons in the maintena nce area prior to selecting appropriate contingency measures. Because it is not possible at this time to determine what control measures will be appropriate at an unspecified time in the future, the list of contingency measures outlined below is not exhaustive. 1) Diesel reduction emission strategies. 2) Alternative fuel (e.g., liquid propane and compre ssed natural gas) and diesel retrofit programs for fleet vehicle operations. 3) Tighter PM 2.5 , SO 2 , and NO x emissions offsets for new and modified major sources. 4) Concrete manufacturing - upgrade wet suppression. 5) Additional NO x RACT statewide. No contingency measure shall be implemented without providing the opportunity for full public participation during which the relative costs and benefits of individual measures, at the time they are under consideration, can be fully evaluated.

D. PM 2.5 , SO 2 , and NO x sources potentially subject to futu re additional control requirements. The following is a list of PM 2.5 , SO 2 , and NO x sources potentially subject to future controls.

• ICI Boilers - SO 2 and NO x controls; • EGUs; • process heaters; • internal combustion engines; • combustion turbines; • other sources greater than 100 tons per year; • Fleet vehicles; • Concrete manufacturers; • Aggregate processing plants.

Page 47 Weirton, WV 1997 PM 2.5 Redesignation and Maintenance PlanVIII. PUBLIC PARTICIPATION West Virginia published notification for a public hearing and solicitation for public comment concerning the draft redesignation petition and main tenance plan in the State Register and the Wheeling Intelligencer on March 2, 2012. The public hearing to receive comments on the re designation request was held at 6:00 p.m. on Tuesday, April 3, 2012, at the West Virginia Di vision of Environmental Protection Headquarters located at 601 57 th Street, SE, Charleston, WV. The public comment period closed on April 3, 2012. No oral comments were received, written comments were received from EPA. Appendix F includes a copy of the public notice, a c opy of the State Register and Wheeling Intelligencer ads, the public hearing transcript, a copy of the comments received and the response to comments.

Page 48 Weirton, WV 1997 PM 2.5 Redesignation and Maintenance PlanIX. CONCLUSIONS

The Weirton PM 2.5 nonattainment area has attained the 1997 annual and 24-hour NAAQS for PM 2.5 and complied with the applicable provisions of the 1990 Amendments to the CAA regarding redesignations of PM 2.5 nonattainment areas. Documentation to th at effect is contained herein. West Virginia DAQ has prepared a redesignation request a nd maintenance plan that meet the requirements of Section 110 (a)(1) of the 1990 CAA. Based on this presentation, the West Virginia portion of the Weirton PM 2.5 nonattainment area meets the requirements for redesignation under the CAA and EPA guidance. West Virginia has performed an analyses showing the air quality improvements are due to permanent and enforceable measures. Furthermore, because this area is subject to signi ficant transport of pollutants, significant regional SO 2 and NO x reductions will ensure continued compliance (maintenance) with the standard with an increasing margin of safety. The State of West Virginia hereby requests that the Weirton 1997 PM 2.5 nonattainment area be redesignated to attainment simultaneously with EPA approval of the CAA section 175A maintenance plan provisions contained herein.

Page 49 Weirton, WV 1997 PM 2.5 Redesignation and Maintenance Plan