John R. Kasich, Governor

Mary Taylor, Lt. Governor

Scott J. Nally, Director



## MAR 15 

## 2013

Susan Hedman Regional Administrator
U.S. EPA, Region 5

77 West Jackson Blvd. R-19J Chicago, Illinois 60604-3507

Re: Request for Review and Approval of the Revised Steubenville-Weirton Area

Maintenance Plan Approval for the 1997 Eight-Hour Ozone Standard

Dear Administrator Hedman:

I am writing to formally request review and approval of a revision to the maintenance plan for

the Ohio portion of the Steubenville-Weirton area (Jefferson County) with respect to the 1997 eight-hour ozone standard. Ohio EPA submitted a redesignation request and maintenance plan for this area on September 22, 2006. U.S. EPA approved this requests May 16, 2007 (72 FR 27652).

Ohio EPA is now requesting a revision to the maintenance plan to update mobile emission projections and conformity budgets based on emission rates generated from U.S. EPA's

latest mobile emissions model, the Motor Vehicle Emission Simulation (MOVES) 2010. In

December 2009, MOVES replaced MOBILE6.2 as the U.S. EPA's official emission factor

model. The area is still attaining and maintaining the 1997 8-hour ozone standard and the point, area and non-road emissions have not changed significantly and did not need to be updated for this submittal.

The enclosed information was compiled by Ohio EPA, Ohio Department of Transportation, and Brooke-Hancock-Jefferson Metropolitan Planning Commission. The public hearing for this package was held on March 4, 2013 in Steubenville, Ohio. No testimony was provided at the public hearing. Comments were received by West Virginia Division of Air Quality. A copy of these comments are provided in Appendix D along with our responses.

50 West Town Street o Suite 700 o P.O. Box 1049 o Columbus, OH 43216-1049
www.epa.ohio.gov • (614) 644-3020 •(614) 644·3184(fax)Administrator Hedman

RE: Request for Review and Approval of the Revised Steubenville-Weirton Area Maintenance Plan Approval for

the 1997 Eight-Hour Ozone Standard
Page 2 of2



### This submittal consists of one ( 1) hard copy of the required documentation. An exact duplicate

electronic version of the submittal in PDF format is available at http://epa.ohio.gov/dapc/SIP/1997 .aspx under the heading" Redesignations and Maintenance

Plans".

If you have any questions, please contact Jennifer Dines in the Division of Air Pollution

Control at (614) 644-3696.

Sincerely,

# ~o~ally Director

enclosures

cc: Bob Hodanbosi, DAPC

Jennifer Dines, DAPC

# REQUEST FOR REDESIGNATION AND
MAINTENANCE PLAN FOR THE OHIO
PORTION OF THE STEUBENVILLEWEIRTON , OH

- WV
EIGHT-HOUR OZONE
NONATTAINMENT AREA

Jefferson County

, Ohio

(Steubenville-Weirton, OH-WV: Jefferson County)



# Developed By: Ohio Environmental Protection Agency
Division of Air Pollution Control in collaboration with West Virginia Department of Environmental

Protection

July 2006

Revised March 2013 1

1 Revised- to update the on -road (highway) emission estimates and Jefferson County (OH) Motor Vehicle Emission Budgets (MVEBs) using the most recent U.S.EPA approved software, MOVES(2010).

### This page left intentionally blanki 

## TABLE OF CONTENTS

Chapter One

Introduction

..................................................................................................................................... 1 Background

..................................................................................................................................... 1 Geographical description

................................................................................................................ 2 Status of air quality

.......................................................................................................................... 2

Chapter Two Requirements for redesignation

...................................................................................................... 3

Chapter Three Ozone monitoring

............................................................................................................................ 6 Ambient data quality assured

.......................................................................................................... 7 Three complete years of data

......................................................................................................... 7 Commitment to continue monitoring

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

Chapter Four Emission Inventory

........................................................................................................................ 10 Base Year Inventory

...................................................................................................................... 10 Emission Projections

..................................................................................................................... 11
Demonstration of Maintenance

..................................................................................................... 16
Permanent and Enforceable Emissions Reductions

.................................................................... 22 Provisions for Future Updates

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

Chapter Five Control measures and regulations

................................................................................................ 24 Implementation of Past SIP Revisions

......................................................................................... 24
New Source Review Provisions

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

As surance of continued controls

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

Chapter Six Contingency measures

................................................................................................................. 28 Commitment to revise plan

........................................................................................................... 28 Commitment for contingency measures

....................................................................................... 28 Potential contingency measures

................................................................................................... 29
List of VOC and NO

x



### sources

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

Chapter Seven Public participation

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

Chapter Eight
Conclusions

................................................................................................................................... 33ii 

### FIGURES

Figure 1 Steubenville-Weirton, OH-WV: Jefferson County Basic Nonattainment Area

....... 6

TABLES

Table 1 Monitoring Data for Steubenville-Weirton, OH-WV: Jefferson Co. 2002

– 2004

... 8

Table 2 Mo nitoring Data for Wheeling, WV-OH: Jefferson County 2003 - 2005

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

Table 3 Emission Estimations for On-road Mobile Sources for Jefferson Co. OH

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

Table 4 Emission Estimations for On-road Mobile Sources for Brooke Co. WV

.............. 14
Table 5 Emission Estimations for On-road Mobile Sources for Hancock Co. WV

............ 14
Table 6 Combined Emission Estimations for On-road Mobile Sources

............................ 15 Table 7 Mobile Vehicle Emission Budgets

......................................................................... 15 Table 8 VOC Emission Inventory Jefferson Co. OH

.......................................................... 17 Table 9 VOC Emission Inventory Combined Hancock and Brooke Co. WV

.................... 18 Table 10 VOC Emission Inventory Steubenville-Weirton, OH-WV: Combined Totals

........ 18

Table 11 NO

x



### Emission Inventory Jefferson Co. Ohio

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

Table 12 NO

x



### Emission Inventory Combined Hancock and Brooke Co. WV

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

Table 13 NO

x



### Emission Inventory Steubenville-Weirton, OH-WV: Combined Totals

......... 20 Table 14 Projected emission estimates 2004 -2018 Jefferson Co. Ohio

............................. 20 Table 15 Projected emission estimates 2004- 2018 Combined Hancock/ Brooke Co. WV 21 Table 16 Projected emission estimates 20 04

- 2018 Combined VOC/NOx Totals

............... 21 Table 17 Combined comparison of 2002 and 2004 On-road and EGU Totals

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

APPENDICES

A Aerometric Information Retrieval System (AIRS) Data

B Emission Inventories C Emissions Analysis Method D Public Participation Documentationiii 

### This page left intentionally blank1 

### REQUEST FOR REDESIGNATION AND

MAINTENANCE PLAN FOR OZONE ATTAINMENT

IN THE EIGHT-HOUR OZONE BASIC

NONATTAINMENT AREA

Steubenville-Weirton, OH-WV: Jefferson County



## CHAPTER ONE

Introduction The Clean Air Act (CAA) requires areas failing to meet the National Ambient Air Quality Standard (NAAQS) for ozone to develop State Implementation Plans (SIP’s) to expeditiously attain and maintain the standard. In 1997, the United States Environmental Protection Agency (U.S. EPA) revised the air quality standards for ozone replacing the 1979 one-hour standard with an eight-hour ozone standard set at 0.08 parts per million (ppm). The standard was challenged legally and upheld by the U.S. Supreme Court in February of 2001.

On April 15, 2004, U.S. EPA designated 134 nonattainment areas for the eight-hour ozone standard. Since that time, U.S. EPA has reclassified nine of the 134 original nonattainment areas to the next lower classification. Section 107(d)(3)(E) of the CAA allows states to request nonattainment areas be redesignated to attainment providing certain criteria are met. The following are the criteria that must be met in order for an area to be redesignated

from nonattainment to attainment:

i) A determination that the area has attained the eight- hour ozone standard. ii) An approved State Implementation Plan (SIP) for the area under Sectio n 110(k ). iii) A determination that the improvement in air quality is due to permanent and enforceable reductions in emissions resulting from implementation of the SIP and other federal requirements. iv) A fully approved maintenance plan under Section 175(A). v) A determination that all Section 110 and Part D requirements have been

met.

BackgroundJefferson County, Ohio, Hancock and Brooke Counties in WV form the SteubenvilleWeirton, OH-WV interstate nonattainment area and constitute the Steubenville, OH Metropolitan Statistical Area. As part of the 1990 CAA Amendments re-evaluation, Steubenville-Weirton, OH-WV: Jefferson County was designated as Unclassifiable/Attainment for the one-hour ozone standard pursuant to the CAA and therefore, has not previously been subject to nonattainment area rule-makings. As a result of the 2004 ozone designations, U.S. EPA designated Steubenville-Weirton, OH-WV: Jefferson County basic nonattainment and subject to the eight-hour ozone requirements, including development of a plan to reduce volatile organic compounds (VOCs) and oxides2



### of nitrogen (NO
x 

### ) emissions and a demonstration that the area will meet the federal eighthour air quality standard for ozone by June 2009.

T his document is intended to support Ohio’s request that the Steubenville-Weirton, OHWV: Jefferson County area be redesignated from nonattainment to attainment for the eight-hour ozone s ta ndard. Steubenville-Weirton, OH-WV: Jefferson County has recorded three (3) years of complete, quality-assured ambient air quality monitoring data for the

years 2002

– 2004 dem onstrating attainment of the eight-hour ozone standard.

Geographical Description Jefferson County is located in eastern Ohio and contains the city of Steubenville. Jefferson County is bordered by Columbiana County to the north, Jefferson to the south, Caroll and Harrison to the west and Hancock, Brooke and Ohio Counties in West Virginia to the east.

This area is shown is shown in Figure 1

.

Status of Air Quality

Ozone monitoring data for the most recent three (3) years, 2002 through 2004

, demonstrates that the air quality has met the NAAQS for ozone in this b as ic nonattainment area. The NAAQS attainment, accompanied by decreases in emission levels discussed in Chapter four, supports a redesignation to attainment for Steubenville-Weirton, OH-WV: Jefferson County based on requirements in Section 107(d)(3)(E) of the CAA.3



## CHAPTER TWO

Requirements for Redesignation U.S. EPA has published detailed guidance in a document entitled Procedures for Processing Requests to Redesignate Areas to Attainment (redesignation guidance ), issued September 4, 1992, to Regional Air Directors. This request for redesignation and maintenance plan is based on the redesignation guidance, supplemented with additional guidance received from staff of U.S. EPA Region V.

Below is a summary of each redesignation criterion as it applies to SteubenvilleWeirton, OH-WV: Jefferson County.

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

The second component relies upon supplemental U.S. EPA-approved air quality modeling. The supplemental modeling is not required for ozone nonattainment areas seeking redesignation. Therefore, this ozone redesignation request for Steubenville-Weirton, OH-WV: Jefferson County does not include modeling data. However, in Appendix C the most recent modeling results showing future attainment and maintenance are provided. Chapter three discusses this requirement in more detail and provides the

attainment demonstration.

ii.) SIP approval: The SIP for the area must be fully approved under Section 110(k) and must satisfy all requirements that apply to the area. Ohio’s SIP was approved on May 9, 1994 (59FR23799) March 23, 1995 (60FR15235) and includes Steubenville-Weirton, OH-WV: Jefferson County. Chapter five discusses this requirement in more detail and provides the attainment demonstration.

iii.) Permanent and enforceable improvement in air quality; The state must be able to reasonably attribute the improvement in air quality to emission reductions which are permanent and enforceable. The state should estimate the percent reduction achieved from federal measures as well as control measures that have been adopted and implemented by the

state.4



### Steubenville-Weirton, OH-WV: Jefferson County was not designatednonattainment for ozone as part of the 1990 CAA Amendments reevaluation. As a result, Ohio has not adopted or implemented control measures beyond the federal measures, the initial 1979 statewide rules and those 1994 and 1995 rules which applied to “rural” attainment areas. Chapters four and five discuss this requirement in more detail and provide

the attainment demonstration.

iv.) Section 110 and Part D requirements: For purposes of redesignation, a state must meet all requirements of Section 110 and part D that were applicable prior to submittal of the complete redesignation request.

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

i.) Section 172(c) requirements This section contains general requirements for nonattainment plans.

The requirements for reasonable further progress, identification of certain emissions increases, and other measures needed for attainment will not apply for redesignations because they only have meaning for areas not attaining the standard. The requirements for an emission inventory will be satisfied by the inventory requirements of the maintenance plan.

ii.) Conformity The state must work with U.S. EPA to show that its SIP provisions are

consistent with section 176(c)(4) conformity requirements. The redesignation request should include conformity procedures, if the state already has these procedures in place. If a state does not have conformity procedures in place at the time that it submits a redesignation request, the state must commit to follow U.S. EPA ’s conformity regulation upon issuance, as applicable. Chapter five discusses this requirement in more detail and provides the attainment

demonstration.

v.) Maintenance plans. Section 107(d)(3)(E) stipulates that for an area to be redesignated, U.S. EPA must fully approve a maintenance plan which meets the requirements of Section 175(A). The maintenance plan will constitute a SIP revision and must provide for maintenance of the relevant NAAQS in the area for at least

10 years after redesignation. Section 175 (A) further states that the plan shall contain such additional measures, if any, as may be necessary to

ensure such maintenance.5



### In addition, the maintenance plan shall contain such contingency measures as the Administrator deems necessary to ensure prompt correction of any violation of the NAAQS. At a minimum, the contingency measures must include a requirement that the state will implement all measures contained in the nonattainment SIP prior to redesignation.

States seeking redesignation of a nonattainment area should consider the following provisions:

a.) attainment inventory; b.) maintenance demonstration; c.) monitoring network; d.) verification of continued attainment; and e.) c ontingency plan.

Chapter six discusses this requirement in more detail and provides the

attainment demonstration.6



## CHAPTER THREE

OZONE MONITORING CAA Section107 (d)(3)(E)(i)

Requirement 1 of 4 : A demonstration that the NAAQS for ozone, as published in 40 CFR 50.4, has been attained. Ozone monitoring data must show that violations of the ambient standard are no longer occurring.

Background : There are two monitors measuring ozone concentrations in this

no nattainment area. The primary monitor is located in Steubenville, Ohio and

is operated by O hio EPA’s Southeast District Office, Division of Air Pollution
Control. Data from a monitor located in Weirton

, West Virginia is also included for the eight-hour ozone attainment demonstration. The Weirton monitor is operated by the West Virginia Department of Environmental Protection (DEP), Division of Air Quality (DAQ), Northern Panhandle Regional Office. A listing of the four (4) highest readings from 2002 through

2004 is shown in Table 1 and readings from 2003-2005 are shown in Table 2. These readings were retrieved from the U.S. EPA air quality system (AQS.) The locations of the monitoring sites for this nonattainment area are shown on Figure 1.

Demonstration :

Figure 1 Steubenville-Weirton, OH-WV: Jefferson County Basic

Nonattainment Area7



### Requirement 2 of 4 : Ambient monitoring data quality assured in accordance with 40 CFR 58.10, recorded in the U.S. EPA air quality system (AQS) database, and available for public view.

Demonstration : Ohio EPA and WV DEP have quality assu re d all data shown in Appendix A
in accordance with 40 CFR 58.10 and all other federal requirements. Ohio

EPA and WV DEP have recorded the data in the AQS database an d therefore data are available to the public.

Requirement 3 of 4 : A showing that the three-year average of the fourth highest values, based on data from all monitoring sites in the area or its affected downwind environs, are below 85 parts per billion (ppb). This showing must rely on three (3) complete, consecutive calendar years of quality assured data.

Background : The following information is taken from U.S. EPA's "Guideline on Data Handling Conventions for the eight- hour Ozone National Ambient Air Quality Standard (NAAQS)," U.S. EPA-454/R- 98 -017, December 1998.

Three (3) complete years of ozone monitoring data are required to demonstrate attainment at a monitoring site. The eight- hour primary and secondary ozone ambient air quality standards are met at an ambient airquality monitoring site when the three-year average of the annual fourthhighest daily maximum eight- hour average ozone concentration is less than or equal to 0.08 ppm. When this occurs, the site is said to be in attainment. Three (3) significant digits must be carried in the computations. Because the third decimal digit, in ppm, is rounded, 0.084 ppm is the largest concentration that is less than or equal to 0.08 ppm. Therefore, for the purposes of this request, the eight-hour standard is considered to be 0.085 ppm. Values

below 0.085 ppm meet the standard, values equal to or greater than 0.085 ppm exceed the standard. These data handling procedures are applied on an individual basis at each monitor in the area. An area is in compliance with the eight- hour

ozone NAAQS if, and only if, every monitoring site in the area meets the NAAQS. An individual site's three (3) year average of the annual fourth highest daily maximum eight- hour average ozone concentration is also

c alled the site's design value. Table 1 shows the monitoring data for 2002

– 2004 and Table 2 show the monitoring data for 2003- 2005 at the

nonattainment area sites and was retrieved from the U.S. EPA AQS. The air quality design value for the area is the highest design value among all sites

in the area.8



### Demonstration :

Table 1 Monitoring Data for Steubenville-Weirton, OH-WV: Jefferson County 2002

– 2004

Data source: U. S. EPA Air Quality System (AQS)

http://www.epa.gov/ttn/airs/airsaqs/index.htm

1 st 2 nd 3 rd 4 th 2002

- 2004

AVERAGE SITE ID COUNTY ADDRESS YEAR %OBS 8

- HR 8

- HR 8

- H R 8

- HR

39

- 081

- 0016 JEFFERSON 227 NORTH 5 TH 2002 100 .099 .099 .093 .093

39

- 081

- 0016 JEFFERSON 227 NORTH 5 TH 2003 99 .107 .097 .090 .079

39

- 081

- 0017 JEFFERSON 618 LOGAN 2004 99 .087 .075 .074 .071

54

- 029

- 1004 HANCOCK (WV) OAK ST & OWIN 2002 99 .099 .097 .097 .097

54

- 029

- 1004 HANCOCK (WV) OAK ST & OWIN 2003 100 .111 .097 .085 .076

54

- 029

- 1004 HANCOCK (WV) OAK ST & OWIN 2004 100 .076 .072 .067 .063
Highest Average .081 ppm



### Table 2 Monitoring Data for Steubenville-Weirton, OH-WV: Jefferson County 2003

– 2005
Data source: U.S. EPA Air Quality System (AQS)

http://www.epa.gov/ttn/airs/airsaqs/index.htm

1 st 2 nd 3 rd 4 th 2003

- 2005

AVERAGE SITE ID COUNTY ADDRESS YEAR % OBS 8

- HR 8

- HR 8

- HR 8

- HR

39

- 081

- 0016 JEFFERSON 227 NORTH 5 TH 2003 99 .107 .097 .090 .079

39

- 081

- 0016 JEFFERSON 227 NORTH 5 TH 2004 99 .087 .075 .074 .071

39

- 081

- 0017 JEFFERSON 618 LOGAN 2005 100 .094 .092 .087 .083

54

- 029

- 1004 HANCOCK (WV) OAK ST & O WIN 2003 100 .100 .092 .083 .077

54

- 029

- 1004 HANCOCK (WV) OAK ST & OWIN 2004 97 .079 .074 .074 .073

54

- 029

- 1004 HANCOCK (WV) OAK ST & OWIN 2005 100 .084 .084 .077 .075
Highest Average 0.77 ppm



### A compr ehensive list of the site’s design values durin g the 2002

- 2004 time period is in Appendix A. The area's design value has trended downward as

emissions have declined due to such factors as cleaner automobiles and fuels both regionally and locally. U.S. EPA ’s rule to control nitrogen oxides from specific source categories (40 CFR Parts 51, 72, 75 and 96, published on October 17, 1998 and referred to as the NO
x 

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

### Budget Trading Program Rule was approved on May 25, 2004 Ohio Administrative Code (OAC ) Chapter 37 45

- 14 . It is expected that this downward trend will continue as the above programs continue and some form of the U.S. EPA Clean Air Interstate Rule (CAIR) is implemented.9



### Requirement 4 of 4 : A commitment that once redesignated, the state will continue to operate an appropriate monitoring network to verify the maintenance of the attainment status.

Demonstration : Ohio EPA and WV DEP commit to continue monitoring ozone levels at the

sites indicated in Figure 1. Ohio EPA and WV DEP will consult with U.S.

EPA Region 5 and Region 3 prior to making changes to the existing monitoring network, should changes become necessary in the future. Ohio

EPA and WV DEP will continue to quality assure the monitoring data to meet the requirements of 40 CFR 58 and all other federal requirements. Connection to a central station and updates to the Ohio EPA W eb site 2 

### will provide real time availability of the data and knowledge of any exceedances. Ohio EPA and WV DEP will enter all data into AQS on a timely basis in accordance with federal guidelines.

2 www .epa.state.oh.us/dapc/10



## CHAPTER FOUR

EMISSION INVENTORY
CAA Section 107 (d)(3)(E)(iii)

U.S. EPA ’s redesignation g uidance requires the submittal of a comprehensive inventory of ozone precursor emissions (VOC and NO
x 

### ) representative of the year when the area achieves attainment of the ozone air quality standard. Ohio also must demonstrate that the improvement in air quality between the year that violations occurred and the year that attainment was achieved is based on permanent and enforceable emission reductions

. Other emissions inventory related requirements include a projection of the emission inventory to a year at least 10 years following redesignation; a demonstration that the projected level of emissions is sufficient to maintain the ozone standard; and a commitment to provide future updates of the inventory to enable tracking of emission levels during the

10 year maintenance period.

Requirement 1 of 5 : A comprehensive emission inventory of the precursors of ozone completed for the base

year.

Background : The point source data are taken from Ohio's annual emissions reporting program. The 2002 periodic inventory has been identified as the preferred data base for SIP development and does coincide with nonattainment air quality in Steubenville-Weirton, OH-WV: Jefferson County.

As part of the NO
x



### SIP Call, the states were required to adopt into their rules a budget for all larg e EGUs. Ohio’s b udget is adopted at OAC Chapter

3745

- 14

. The budget represents a statewide cap on NO
x 

### emissions. These emissions, capped by the state rule, should remain at least this low through the maintenance period covered by this request.

Periodic inventories, which include emissions from all sectors - mobile, area,

non -road, and point sources - are prepared every three (3) years.

Demonstration : While ozone and its precursors are transported into this region from outside areas, this information does provide some indication of the impact from Ohio sources near the nonattainment area. The emissions are decreasing substantially in response to regional and national programs affecting many EGUs such as the Acid Rain program and the NO
x 

### SIP Call. Other sectors of the inventory also impact ozone formation, but large regional sources such as EGUs have a substantial impact on the formation of ozone.11



### Requirement 2 of 5 : A projection of the emission inventory to a year at least 10 years following redesignation.

Background : Ohio EPA prepared a comprehensive inventory for Steubenville-Weirton, OH-WV: Jefferson County, including area, mobile, and point sources for precursors of ozone (VOCs and NO
x 

### ) for base year 2002. The information below describes the procedures Ohio EPA used to generate the 2002 base inventories. These inventories were provided to Lake Michigan Air Directors Consortium (LADCO) and have been processed to develop summer day emissions for use in the air quality analyses. These processed modeling inventories have been identified as the correct iteration of the inventory for use in the redesignation. In this document, references to LADCO include the Midwest Regional Planning Organization.

Area sources were taken from the Ohio 2002 periodic inventory submitted to U.S. EPA. These projections were made from the U.S. Department of Commerce Bureau of Economic Analysis (BEA) growth factors, with some updated local information. Mobile source emissions were calculated from MOVES2010 produced

emiss ion factors. Point source information was compiled from Ohio EPA’s 2002 annual emissions inventory database and the 2002 U.S. EPA Air Markets

acid rain database 3



### . Biogenic emissions are not included in these summaries. Non-road emissions were generated usi ng U.S. EPA ’s National Mobile Inventory Model (NMIM) 2002 application. To address concerns about the accuracy of some of the categories in U.S. EPA ’s

non -road emissions model, LADCO contracted with two (2) companies to review the base data and make recommendations.One of the contractors also estimated emissions for three (3) nonroad categories not included in U.S. EPA ’s non -road model. Emissions were estimated for aircraft, commercial marine vessels and railroads. Recreational motorboat population and spatial surrogates (used to assign emissions to each county) were significantly updated. The populations for the construction equipment category were reviewed and updated based upon surveys completed in the Midwest and the temporal allocation for agricultural sources also was updated.

3 http://www.epa.gov/airmarkets/acidrain12



### Demonstration :

On -Road Emission Estimations

In coordination with the Brooke, Hancock, Jefferson Transportation Study (BHJTS) and the West Virginia Department of Transportation (WVDOT), the Ohio Department of Transportation (ODOT) utilizes a regional travel demand

forecast model to simulate traffic in the area and to forecast traffic flows for given growth expectations. The model is primarily used as a long range planning tool to evaluate the transportation system including determination of locations where additional travel capacity may be needed and to determine the infrastructure requirements necessary to meet that need. It is also used as a tool for air quality purposes to estimate the total emissions of pollution caused by vehicles in the area. The travel demand forecasting model is used to predict the total daily vehicle miles traveled (VMT) and a U.S. EPA computer program called MOVES is used to calculate emissions per mile. The product of these is the total amount of pollution emitted by the on-road vehicles for the particular analyzed area.

Overview

Broadly described, MOVES is used to generate “emission factors”, which are the average emissions per mile (grams/mile) for ozone precursors, NOx and
VOC. The MOVES model includes a number of variables that affect the emission factors. These variables have national default values, some of which require modification to reasonably reflect local conditions. Some of these variables are discussed here. The vehicle fleet (vehicles on the road) age and the vehicle type have a major effect on the emission factors. The source types are traveling on road types (MOVES road types are Rural Restricted Access, Rural Unrestricted Access, Urban Restricted Access, and Urban Unrestricted Access). The vehicle speeds also affect the emission factor values. Meteorological conditions such as air temperature and humidity have a significant effect on emission factors. Emission factors produced by MOVES can also include the effect of emission reduction strategies such as vehicle inspection and maintenance programs, regulation of fuels, etc. These MOVES inputs are estimated using the best available

data.

These inputs are reviewed and agreed to by U.S. EPA and transportation agencies in a formal interagency consultation process. Emission factors are multiplied by VMT from the travel demand model to estimate the total vehicle

emissions.

The emission factors from MOVES can be used with the travel demand model information by combining the disaggregate emission rates with VMT,13



### and source type population for each road type, source type and hour of day, and then sum them up to get the total emissions for the area.

The BHJ TS analysis method, developed by ODOT, is to aggregate the emission rates by two source types (cars & trucks), then applying VMT and source type population, thereby reducing the intensive processes. In the first step emission factors are broadly classified into total vehicles, cars and trucks by pollutant, by average speed, road type and hour of day. Then the hourly link volumes generated from travel demand model are combined with

emission factors for each network link for each hour. The on-road vehicle

emissions for the area are the sum of all individual link-hour emissions. Vehicle-based emissions are obtained by the combination of corresponding emission factors and source type population. Intrazonal emissions are computed using a separate method to account for those trips that use local roads to travel within a zone. Intrazonal VMT is combined with correspondingemission factors to get intrazonal emissions. Total emissions are sum of onroad vehicle emissions, vehicle-based emissions and intrazonal emissions.

Automated programs, using FORTRAN and CUBE scripting, were develo ped by ODOT to generate total emissions. The process uses data on daily and directional traffic distributions as well as more up to date volume/delay functions from the 2000 Highway Capacity Manual (HCM). This process also handles the newer model network formats and MOVES generated emission

factors.

MOVES input and output files are provided in Appendix C.

Best Available Data

Most current vehicle age distribution data, temperature data, fuel properties data, source type distribution data, and I/M data provided by ODOT’s ATRs and WIMs, NOAA, ODPS, and Ohio EPA were used by the ODOT for generating emission factors. Likewise, the most current transportation planning data available from BHJ TS and most current ODOT count data were used by ODOT for the emissions estimates.

Analysis Years

Analysis years for this re-designation request include 2002, 2004, 2009, and 2018 to meet the requirements specified by the CAA and U.S. EPA. The travel demand model presents the transportation system conditions for each

of these years. Model runs for each future analysis year contain the road

network BHJ TS and ODOT expects to exist at the beginning of that year with corresponding socioeconomic forecasts for that year.14



### Local Road VMT

Most local roads such as subdivision streets are not explicitly modeled in a
travel demand model. These local roads are represented as fictitious
roadways called centroid connectors. Local road VMT is included in the ODOT post process by including the traffic loaded on centroid connectors. In
addition, some local road traffic is captured as intra-zonal trips which travel demand models usually do not assign to roadway segments. ODOT post
process includes these trips as local road VMT.

Emission Estimations

Tables 3 through 5 contain the results of the emissions analysis for the appropriate years.

Table 3 - Emission Estimations for On-Road Mobile Sources for Jefferson County, Ohio
Jefferson County 2002 2004 2009 2018
VMT (miles/day) 1,709,448 1,611,125 1,576,635 1,540,060

VOC (tons/day) 6 .61 5.62 4.20 1.86

NOx (tons/day) 7.75 6.69 5.14 2.11

Table 4 - Emission Estimations for On-Road Mobile Sources for Brooke County, West Virginia
Brooke County 2002 2004 2009 2018
VMT (miles/day) 606,195 600,702 602,928 600,944

VOC (tons/day) 1.40 1.20 0.83 0.36

NOx (tons/day) 2.21 1.86 1.28 0.48

Table 5 - Emission Estimations for On-Road Mobile Sources for Hancock County, West Virginia
Hancock County 2002 2004 2009 2018
VMT (miles/day) 561,349 502,239 497,991 495,327

VOC (tons/day) 1.08 0.88 0.58 0.25

NOx (tons/day) 2.02 1.56 1.05 0.3715



### Table 6 Combined VOC and NO
x 

### Emission Estimations for On-Road

Mobile Sources for Jefferson County, OH, Brooke and Hancock County, WV

Data source: On -road only, Ohio DOT Modeling and Forecasting Section.



### Coun ty VOC 2018
Jefferson County, OH VOC 1.86

Brooke County, WV VOC 0.36

Hancock County, WV VOC 0.25

TOTAL VOC 2.47

County NO
x 

### Jefferson County, OH NO
x 

### 2.11

Brooke County, WV NO
x 

### 0.48

Hancock County, WV NO
x 

### 0.37

TOTAL NO
x 

### 2 .96

Motor Vehicle Emission Budget

Table 7 contains the motor vehicle emissions budget for Jefferson County, Ohio.

Table 7 Mobile Vehicle Emissions Budget for Jefferson County, Ohio (Steubenville-Weirton, OH_WV) 4



### Jefferson County 2004 2009 2018 VOC (tons/day) 5.62 4.83 2.14

NO
x 

### (tons/day) 6.69 5.91 2.43

Brooke and Hancock Co. 2009 2018 VOC (tons/day) 2.60 3.40 1.90

NO
x 

### (tons/day) 3.60 4.20 3.90

4 Ohio’s submittal only requests budgets be set for Ohio counties. Current 2004, 2009 and 2018 budgets for West Virginia are identified in Table 7 and subsequent tables. These budgets were set by West Virginia to address the transition to MOVES and U.S. EPA approved these budgets on September 15, 2011 (76 FR 56975). West Virginia does not plan to make any further updates to their ozone budgets).16



### Th e Jefferson County budget includes the emission estimates calculated for

2009 and 2018 and an additional margin of safety. The emission estimates are derived from the Tranplan travel demand model and MOVES 201 0 as described above under the expected Brooke, Hancock, and Jefferson Transportation Study (BHJTS) 2025 Long Range Plan. The mobile source budget includes 4.83 tons/day for VOC in 2009, 2.14 tons/day for VOC in 2018, 5.91 tons/day for NO
x 

### in 2009

, and 2.43 tons/day for NO
x 

### in 2018. These correspond to a 15 percent increase from the on -road emissions for
both VOC and NO
x 

### . Ap pen dix C contains data tables and graphs of these

emissions. Tables 8 through 13 below include the mobile vehicle emission budgets.

All methodologies, latest planning assumptions and the safety margins were determined through the interagency consultation process described in the Transportation Conformity Memorandum of Understanding (MOU) for
BHJTS.

Requirement 3 of 5 : A demonstration that the projected level of emissions is sufficient to maintain the ozone

standard.

Background : In consultation with U.S. E PA , Ohio EPA selected the year 2018 as the maintenance year for this redesignation request. This document contains projected emissions inventories for 2009 and 2018.

Ohio DOT performed emission projections for Steubenville-Weirton, OH-WV: Jefferson County using the following approaches.

Mobile source emission projections are based on the U.S. EPA MOVES 2010model. The analysis is described in more detail in Appendix C. All projections were made in accordance with

“Procedures for P reparing Emissions Pr ojections” U.S. EPA-45/4- 91

- 019.

Emissions inventories are required to be projected to future dates to assess the influence growth and future controls will have. LADCO has developed growth and control files for point, area, and non-road categories. These files were used to develop the future year

emissions estimates used in this document. This was done so the inventories used for redesignation are consistent with modeling performed in the future.17



### The detailed inventory information for Jefferson County for 2004, 2009 and 2018 is in Appendix B. Emission trends are an important gauge for continued compliance with the ozone standard. Therefore, Ohio EPA performed an initial comparison of the inventories for the base year and maintenance years. Mobile source emission inventories are described in Appendix C. In addition to the LADCO estimates, point source emissions were projected based upon the statewide EGU NO
x 

### budgets from the Ohio
NO
x 

### rule. Emission Inventories for Hancock and Brooke Counties in WV used for this request were developed by DEP staff with the support of the contractors for the Visibility Improvement State and Tribal Association of the Southeast (VISTAS), a federally recognized regional planning organization.

The following tables include sectors Electrical Generating Unit (EGU-Point), Non-Electrical Generating Unit (Non-EGU), Non-road Mobile (Non-road), Other Area (Other), Marine, Aircraft, Rail (MAR), On-road Mobile (On-road).

Please note that WV non-road sector includes MAR.

Demo nstration :

Table 8 Jefferson County VOC Emission Inventory Totals for Base

Year 2002 , Estimated 2004 and Projected 2009 and 2018 (tons per day)

Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air Directors Consortium (LADCO) Web site: http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm

. Data source: On -road only, Ohio DOT Modeling and Forecasting Section.



### Sector 2002

Base 2004

A ttainment 2009

Interim 2018

Maintenance Safety

Margin

EGU Point 0.88 0.92 1.03 1.02

Non

- EGU 0.23 0.23 0.22 0.24

Non

- road 0.90 0.88 0.82 0.55

Other 3.12 3.06 2.91 2.91

M AR 0.05 0.05 0.05 0.05

On

- road 6.61 5.62 4.83* 2.14*

TOTAL 11.79 10.76 9. 86 6.91 3.85

* includes 15 percent increase to the mobile source budget18



### Table 9 Combined Hancock and Brooke County VOC Emission Inventory Totals for Base Year 2002 , Estimated 2004 and Projected 2009 and 2018 (tons per day)

Data source: WV emission inventory, Visibility Improvement State and Tribal Association of the Southeast (VISTAS) http://www.vistas -sesarm.org/

. Data source: On -road only, Ohio DOT Modeling and Forecasting Section.



### Sect or 2002

Base 2004

Attainment 2009

Interim 2018

Maintenan ce Safety

Margin

EGU Point n/a n/a n/a n/a

Non

- EGU 6.70 4.80 4.30 5.30

Non

- road (includes MAR) 

### 1.50 1.50 1.20 1.00

Other (Area) 

### 4.50 4.60 4.50 5.20

On

- road 2.48 2.60 3.40 1.90

TOTAL 15.18 13.50 13.40 13.40 0.10

Table 10 Steubenville-Weirton, OH-WV: Combined VOC Emission Inventory Totals for Base Year 2002 , Estimated 2004 and Projected 2009 and 2018 (tons per day)

Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air Directors Consortium (LADCO) Web site: http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm

. Data source: WV emission inventory, Visibility Improvement Sta te and Tribal Association of the

Southeast (VISTAS) http://www.vistas -sesarm.org/

. Data source: On -road only, Ohio DOT Modeling and Forecasting Section.



### 2002

Base 2004

Attainment 2009

Interim 2018

Maintena nce Safety

Margin

Jefferson Co. OH

Total 11.79 10.76 9.86 6.91

Brooke and Hancock

Co. WV Total 15.18 13.50 13.40 13.40

COMBINED VOC

TOTAL 26.97 24.26 23.26 20.31 3.9519



### Table 11 Jefferson County NO
x 

### Emission Inventory Totals for Base Year

2002

, Estimated 2004 and Projected 2009 and 2018 (tons per day)

Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air Directors Consortium (LADCO) Web site: http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm

. Data source: On -road only, Ohio DOT Modeling and Forecasting Section.



### Sector 2002 Base 2004

Attainment 2009

Interim 2018

Maintenance Safety

Margin

EGU Point 183.99 148.80 60.77 40. 95

Non

- EGU 6.05 5.93 5.63 5.43

Non

- road 0.77 0.72 0.58 0.33

Other 0.17 0.18 0.21 0.21

M AR 1.60 1.53 1.35 1.25

On

- road 7.75 6.69 5.91* 2.43*

TOTAL 200.33 163.85 74.45 50.60 113.25

* includes 15 percent increase to the mobile source budget

Table 12 Combined Hancock and Brooke County NO
x 

### Emission Inventory Totals for Base Year 2002

, Estimated 2004 and Projected 2009 and 2018 (tons per day)

Data source: WV emission inventory, Visibility Improvement State and Tribal Association of the

Southeast (VISTAS) http://www.vistas -sesarm.org/

. Data source: On -road only, Ohio DOT Modeling and Forecasting Section.



### Sector 2002

Base 2004

Attainment 2009

Interim 2018

Maintenance Safety

Margin

EGU Poin t n/a n/a n/a n/a

Non

- EGU 5.90 4.50 5.10 5.60

Non

- road (includes MAR) 

### 4.30 5.30 3.80 3.20

Other (Area) 

### 4.6 0 4.80 4.90 5.20

On

- road Hancock 4.23 3.60 4.20 3.90

TOTAL 19.03 18. 20 18.00 17.90 0.3020



### Table 13 Steubenville-Weirton, OH-WV: Co mbined NO
x 

### Emission Inventory Totals for Base Year 2002 , Estimated 2004 and Projected 2009 and 2018 (tons per day)

Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air Directors Consortium (LADCO) Web site:

http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm

. Data source: WV emission inventory, Visibility Improvement State and Tribal Association of the

Southeast (VISTAS) http://www.vistas -sesarm.org/

. Data source: On -road only, Ohio DOT Modeling and Forecasting Section.



### 2002

Base 2004

Attainment 2009

Interim 2018

Maintenance Safety

Margin

Jefferson Co. OH

Total 200.33 163.85 74.45 50.60

Hancock and Brooke

Co. WV Total 19.03 18 .20 18.00 17.90

COMBINED NO
x 

### TOTAL 219.36 182.05 92.45 68.50 113. 55

Table 14 Jefferson County Comparison of 2004 attainment year and 2018 projected emission estimates (tons per day, summer)

Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air Directors Consortium (LADCO) Web site:

http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm

. Data source: On -road only, Ohio DOT Modeling and Forecasting Section.



### 2004 2018 Projected

Decrease

VOC 10.76 6.91 3.85

NO
x 

### 163.85 50.60 113.2521



### Table 15 Combined Hancock and Brooke County Comparison of 2004

attainment year and 2018 projected emission estimates (tons per day, summer)

Data source: WV emission inventory, Visibility Improvement State and Tribal Association of the Southeast (VISTAS) http://www.vistas -sesarm.org/

. Data source: On -road only, Ohio DOT Modeling and Forecasting Section.



### 2004 2018 Projected

Decrease

VOC 13.50 13.40 0.10

NO
x 

### 18. 20 17.90 0.30

Table 16 Steubenville-Weirton, OH- WV Combined Comparison of 2004

attainment year and 2018 projected emission estimates (tons per day, summer)

Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air Directors Consortium (LADCO) Web site:

http://www.ladco.org/tech/emis/basek/BaseK _Reports.htm

. Data source: WV emission inventory, Visibility Improvement State and Tribal Association of the Southeast (VISTAS) http://www.vistas -sesarm.org/

. Data source: On -road only, Ohio DOT Modeling and Forecasting Section.



### 2004 2018 Projected

Decrease

Combined VOC Total 24.26 20.31 3. 95

Combined NOx Total 182.05 68.50 113.55

VOC emissions in the non-attainment area are projected to decrease by 3.95

tons

. Area source emissions and, to a lesser extent, point sources, show an increase due to expectations that the population will grow in this area. However, cleaner vehicles and fuels are expected to be in place in 2009 and 2018 and result in an overall drop in VOC emissions.

NO
x 

### emissions in the nonattainment area are projected to decrease by

113.55 tons. Decreases from U.S. EPA rules covering Tier 2 Motor Vehicle Emissions Standards and Gasoline Sulfur Control Requirements 5 

### , Highway Heavy-Duty Engine Rule 6 

### and Non-Road Diesel Engine Rule 7 

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

### SIP

5 http://www.epa.gov/fedrgstr/EPA-AIR/2000/February/Day-10/a19a.htm

6 http://www.epa.gov/fedrgstr/EPA-AIR/1997/October/Day-21/a27494.htm

7 http://www.epa.gov/fedrgstr/EPA-AIR/1998/October/Day-23/a24836.htm22



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

### and ozone levels entering this

area also will be decreased.

Requirement 4 of 5 : A demonstration that improvement in air quality between the year violations occurred and attainment was achieved is based on permanent and enforceable emission reductions and not on temporary adverse economic conditions or unusually favorable meteorology.

Background : Ambient air quality data from all monitoring sites indicate that air quality met
the NAAQS for ozone in 2004 . U.S. EPA ’s redesignation g uidance (p 9) states, “A state may generally demonstrate maintenance of the NAAQS by either showing that future emissions of a pollutant or its precursors will not exceed the level of the attainment inventory, or by modeling to show that the

future mix of sources and emissions rates will not cause a violation of the
NAAQS.”

In Ohio, major point sources in all counties are required to submit air emissions information once every three (3) years or annually if VOC potential to emit is greater than 250 tons or NO
x 

### potential to emit is greater than 2500

t ons, in accordance with U.S. EPA’s Consolidated Emissions Reporting Rule (CERR). Ohio U.S. EPA prepares a new periodic inventory for all ozone precursor emission sectors every three (3) years. These ozone precursor inventories will be prepared for 2005, 2008, and 2011 as necessary to comply with the inventory reporting requirements established in the CFR. Emissions information will be compared to the 2002 base year and the 2018 projected maintenance year inventories to assess emission trends, as necessary, to assure continued compliance with the ozone standard.

Demonstration : Permanent and enforceable reductions of volatile organic compounds and oxides of nitrogen have contributed to the attainment of the eight- hour ozone standard. Some of these reductions were due to the application of tighter federal standards on new vehicles. Also, Title IV of the CAA and the NO
x 

### SIP Call required the reduction of oxides of nitrogen from utility sources.23



### Table 17 Steubenville-Weirton, OH- WV Combined Comparison of 2002

base year and 2004 attainment year on-road and EGU

reductions

Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air Directors Consortium (LADCO) Web site:

http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm

. Data source: WV emission inventory, Visibility Improvement State and Tribal Association of the

Southeast (VISTAS) http://www.vistas -sesarm.org/

. Data source: On -road only, Ohio DOT Modeling and Forecasting Section



### 2002 2004

On

- road VOC 9 .09 8.22

On

- road NO
x 

### 11.98 10.29

EGU NO
x 

### 183.99 148.80

Requirement 5 of 5 : Provisions for future annual updates of the inventory to enable tracking of the emission levels including an annual emission statement from major sources.

Demonstration : As required by Section 175A(b) of the CAA, Ohio commits to submit to the Administrator, eight (8) years after redesignation, an additional revision of this SIP. The revision will contain Ohio's plan for maintaining the national primary ozone air quality standard for 10 years beyond the first 10 year period after redesignation.24



## CHAPTER FIVE

CONTROL MEASURES AND REGULATIONS
CAA Section 107 d)(3)(E)(ii), 107(d)(3)(iv) & 107(d)(3)(E)(v)

Requirement 1 of 4: A U.S. EPA approved SIP control strategy that includes Reasonably Available Control Technology (RACT) requirements for existing stationary sources covered by Control Technology Guidelines (CTG) as applied in Ohio’s rural counties.

Background : As required by Section 172 of the 1990 CAA Amendments, in the mid- 1990’s Ohio promulgated rule requiring RACT for emissions of VOCs. There were no

s pecific rules required by the CAA such as RACT for existing sources beyond

statewide rules.

Demonstration : Statewide RACT rules have been applied to all new sources locating in Ohio since that time. The Ohio rules are found in OAC Chapter 3745- 21.

Requirement 2 of 4: Evidence that control measures required in past ozone SIP revisions have been fully implemented.

Background : The U.S. EPA NO
x



### SIP Call required 22 states to pass rules that would result in significant emission reductions from large EGUs, industrial boilers, and cement kilns in the eastern United States. Ohio passed this rule in 2001.

Be ginning in 2004, this rule accounts for a reduction of approximately 31 percent of all NO
x



### emissions state-wide compared to previous uncontrolled years. The other 21 states also have adopted these rules.

Demonstration : U.S. EPA and Ohio EPA performed modeling that indicated this area would attain the eight- hour ozone standard with the implementation of the NO
x 

### SIP Call. Controls for EGUs 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 U. S. EPA
Clean Air Markets W eb site, quantifies the gradual NO
x 

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

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

### Budget Trading Program rules in OAC Chapter 3745-14 in response to the SIP Call. OAC chapter 3745-14 regulated EGUs and certain non -EGUs under a cap and trade program based on an 85 percent reduction of NOx emissions from25



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

### emissions from non-EGUs, compared to historical levels. This cap will stay in place through 2008, at which time the CAIR program will supersede it.

U.S. EPA has recently published Phase II of the NO
x 

### SIP Call that establishes a budget for large (greater than 1 ton per day emissions) stationary internal combustion engines. Ohio EPA’s proposed rule OAC

3745

- 14 -12 addresses stationary internal combustion engines, all used in natural gas pipeline transmissions. An 82 percent NO
x 

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

### emissions will be 599 tons per day.

Tier II Emission Standards for Vehicles and Gasoline Sulfur Standards In February 2000

, U.S. EPA finalized a federal rule to significantly reduce emissions from cars and light trucks, including sport utility vehicles (SUVs). Under this proposal, automakers will be required to sell cleaner cars, and refineries will be required to make cleaner, lower sulfur gasoline. This rule will apply nationwide. The federal rules will phase in between 2004 and
2009. U.S. EPA has estimated that NO
x 

### emission reductions will be approximately 77 percent for passenger cars, 86 percent for smaller SUVs, light trucks, and minivans, and 65 to 95 percent reductions for larger SUVs, vans, and heavier trucks. VOC emission reductions will be approximately 12 percent for passenger cars, 18 percent for smaller SUVs, light trucks, and minivans, and 15 percent for larger SUVs, vans, and heavier trucks.

Heavy-Duty Diesel Engines In July 2000, U.S. EPA issued a final rule for Highway Heavy Duty Engines, a program which includes low-sulfur diesel fuel standards, which will be phased in from 2004 through 2007. This rule applies to heavy-duty gasoline and diesel trucks and buses. This rule will result in a 40 percent reduction in
NO
x 

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

### inventory.

Clean Air Non-road Diesel Rule In May 2004, U.S. EPA issued the Clean Air Non-road Diesel Rule. This rule applies to diesel engines used in industries such as construction, agriculture, and mining. It also contains a cleaner fuel standard similar to the highway diesel program. The new standards will cut emissions from non-road diesel engi nes 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 current levels, from

appr oximately 3,000 parts per million (ppm) now to 15 ppm in 2009. New engine standards take effect, based on engine horsepower, starting in 2008.26



### Together, these rules will substantially reduce local and regional sources of

ozone precursors.

Requirement 3 of 4: Acceptable provisions to provide for new source review.

Background : Ohio has a long standing and fully implemented New Source Review (NSR) program. This is addressed in OAC Chapter 3745-31. The chapter includes provisions for the Prevention of Significant Deterioration (PSD) permitting program in OAC 3745- 31 -01 to 3745- 31 -20. Ohio's PSD program was conditionally approved on October 10, 2001 (66 FR 51570) and received final approval on January 22, 2003 (68FR 2909) by U.S. EPA as part of the
SIP.

Demonstration : Any facility that is not listed in the 2002 emission inventory, or for the closing of which credit was taken in demonstrating attainment, will not be allowed to construct, reopen, modify, or reconstruct without meeting all applicable permit rule requirement. The review process will be identical to that used for new sources. Once the area is redesignated, Ohio EPA will implement NSR through the PSD program.

Requirement 4 of 4: Assure that existing controls will remain in effect after redesignation unless the State demonstrates through photochemical modeling that the standard can be maintained without one (1) or more controls.

Demonstration : Ohio commits to maintaining the aforementioned control measures after redesignation. Ohio hereby commits that any changes to its rules or emission limits applicable to VOC and/or NO
x 

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

revision.

Ohio, through Ohio EPA’s Legal section, has the legal authority and necessary resources to actively enforce any violations of its rules or permit provisions. After redesignation, it intends to continue enforcing all rules that relate to the emission of ozone precursors in Steubenville-Weirton, OH-WV: Jefferson County.27



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

LADCO performed modeling to evaluate the effect of the NO
x 

### SIP Call and Tier II / Low Sulfur rule for future year 2007 ozone in the Lake Michigan area. This modeling was originally designed to assess the one-hour ozone standard. Further analysis was conducted and documented in the LADCO’s White Paper “8 -Hour Ozone Assessment” dated May 2, 2001. Base year design values used were the average of the design values for the three (3) three-year periods (1994-1996, 1995- 1997, and 1996 -1998). Base year emissions were taken from 1996 and four (4) ozone episodes were evaluated: June 22-28, 1991; July 14-21, 1991; June 13-25, 1995; and July 7-18, 1995.

While modeling results were not calculated for Steubenville-Weirton, OH-WV: Jefferson County, the average decrease in ozone from the base case modeling run with modeling runs that applied emission controls required by the CAA

, NO
x 

### SIP Call and Tier II /low-sulfur requirements was nine (9) ppb.

LADCO Modeling for CAIR of 2004

On March 10, 2004 , the U.S. EPA promulgated the CAIR. NO
x 

### emissions will 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 eastern states and the District of Columbia.

LADCO performed modeling to support the associated emission reductions for CAIR. This modeling was based on 2001

– 2002 design values for SteubenvilleWeirton, OH-WV: Jefferson County. Results of the CAIR modeling showSteubenville-Weirton, OH-WV: Jefferson County will continue to attain the eighthour ozone NAAQS well into the future.28



## CHAPTER SIX

CONTINGENCY MEASURES CAA Section 107(d)(3)(E)(v)

Requirement 1 of 4: A commitment to submit a revised plan eight (8) years after redesignation.

Demonstration : Ohio hereby commits to review its maintenance plan eight (8) years after redesignation, as required by Section 175(A) of the CAA

.

Requirement 2 of 4: A commitment to expeditiously enact and implement additional contingency control measures in response to exceeding specified predetermined levels (triggers) or in the

event that future violations of the ambient standards occur.

Demonstration : Ohio hereby commits to adopt and expeditiously implement necessary corrective actions in the following circumstances:

Warning Level Response: A warning level response shall be prompted whenever an annual (1-year) fourth high monitored value of 88 ppb occurs in a single ozone season within the maintenance area. A warning level response will consist of a study to determine whether the ozone value indicates a trend toward higher ozone values or whether emissions appear to be increasing. The study will evaluate whether the trend, if any, is likely to continue and, if so, the control measures necessary to reverse the trend taking into consideration ease and timing for implementation as well as economic and social considerations. Implementation of necessary controls in response to a warning level response trigger will take place as expeditiously as possible, but in no event

later than 12 months from the conclusion of the most recent ozone season (September 30).

Should it be determined through the warning level study that action is necessary to reverse the noted trend, the procedures for control selection

and implementation outlined under action level response shall be followed.

Action Level Response

An action level response shall be prompted whenever a two (2) year average fourth high monitored value of 85 ppb occurs within the maintenance area. In the event that the action level is triggered and is not due to an exceptional event, malfunction, or noncompliance with a permit condition or rule29



### requirement, Ohio EPA will determine additional control measures needed to assure future attainment of NAAQS for ozone. In this case, measures that can be implemented in a short time will be selected in order to be in place within eighteen (18) months from the close of the ozone season that prompted the action level.

Control Measure Selection and Implementation

Adoption of any additional control measures is subject to the necessary administrative and legal process. This process will include publication of notices, an opportunity for public hearing, and other measures required by Ohio law for rulemaking by state environmental boards.

If a new measure/control is already promulgated and scheduled to be implemented at the federal or state level, and that measure/control is determined to be sufficient to address the upward trend in air quality, additional local measures may be unnecessary. Furthermore, Ohio will submit to U.S. EPA an analysis to demonstrate the proposed measures are adequate to return the area to attainment.

Requirement 3 of 4: A list of potential contingency measures that would be implemented in such an event.

Demonstration : Contingency measures to be considered will be selected from a comprehensive list of measures deemed appropriate and effective at the

time the selection is made. The selection of measures will be based on costeffectiveness, emission reduction potential, economic and social considerations or other factors that Ohio EPA deems appropriate. Ohio EPA will solicit input from all interested and affected persons in the maintenance area prior to selecting appropriate contingency measures. Because it is not possible at this time to determine what control measure will be appropriate at an unspecified time in the future, the list of contingency measures outlined below is not comprehensive.

1) Lower Reid vapor pressure gasoline program.

2) Tighten RACT on existing sources covered by U.S. EPA Control Technique Guidelines issued in response to the 1990 CAA.

3) Apply RACT to smaller existing sources.

4) One or more transportation control measures sufficient to achieve at

le ast half a percent reduction in actual area wide VOC emissions. Transportation measures will be selected from the following, based30 

### upon the factors listed above after consultation with affected local governments:

a) trip reduction programs, including, but not limited to, employerbased transportation management plans, area wide rideshare programs, work schedule changes, and telecommuting:

b) traffic flow and transit improvements:

c) other new or innovative transportation measures not yet in widespread use that affects state and local governments deemed appropriate.

5) Alternative fuel and diesel retrofit programs for fleet vehicle operations.

6) Controls on consumer products consistent with those adopted
elsewhere in the United States.

7) Require VOC or NO
x 

### emission offsets for new and modified major

sources.

8) Require VOC or NO
x 

### emission offsets for new and modified minor

sources.

9) Increase the ratio of emission offsets required for new sources.

10) Require VOC or NO
x 

### controls on new minor sources (less than 100 tons).

No contingency measure shall be implemented without providing the opportunity for full public participation during which the relative costs and benefits of individual measures, at the time they are under consideration, can be fully evaluated.

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



### sources potentially subject to future controls.

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

### sources potentially subject to future

controls.

NO
x 

### RACT

EGUs asphalt batching plants31



### industrial/commercial and institutional boilers process heaters internal combustion engines

combustion turbines other sources greater than 100 tons per year

VOC RACT consumer products architectural and industrial maintenance coatings stage I gasoline dispensing facilities (including pressure valves) automobile refinishing shops cold cleaner degreasers portable fuel containers synthetic organic compound manufacturi ng organic compound batch processes wood manufacturing

industrial wastewater aerospace industry shipbuilding

bakeries plastic parts coating volatile organic liquid storage industrial solvent cleaning offset lithography industrial surface coating other sources greater than 50 tons per year32



## CHAPTER SEVEN

PUBLIC PARTICIPATION

Ohio published notification for a public hearing and solicitation for public comment concerning the draft redesignation petition and maintenance plan in the widely distributed county pub lications

.

The public hearing to receive comments on the redesignation request was held on March 4, 2013 , at the Steubenville Schiappa Branch Library, located at 4141 Mall Drive, in Steubenville, Ohio. The public comment period closed on March 4, 2013

. Appendix D will include a copy of the public notice, response to comments, and the transcript from the public hearing.33



## CHAPTER EIGHT

CONCLUSIONS

The Steubenville-Weirton, OH-WV: Jefferson County basic nonattainment area has attained the NAAQS standard and complied with the applicable provisions of the 1990 Amendments to the CAA regarding redesignations of basic ozone nonattainment areas. Documentation to that effect is contained herein. Ohio EPA has prepared a state implementation and maintenance plan that meets the requirement of Section 110 (a)(1) of
the 1990 CAA

.

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

### reductions will ensure continued compliance (maintenance) with the standard and that all CAA requirements necessary for redesignation have been met.

Based on this presentation, the Steubenville-Weirton, OH-WV: Jefferson County ozone

ba sic nonattainment area meets the requirements for redesignation under the CAA and U.S. EPA guidance. Furthermore, because this area is subject to significant transport of pollutants, significant regional NO
x 

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

The State of Ohio hereby requests that the Steubenville-Weirton, OH-WV: Jefferson County ozone basic nonattainment area be redesignated to attainment simultaneously with U.S. EPA approval of the Ohio s tate implementation and maintenance plan provisions

contained herein.

### This page left intentionally blank

### Synopsis of Changes

Revised Steubenville-Weirton Maintenance Plan under the 1997 Ozone Standard

The original redesignation request and maintenance plan document was submitted to U.S. EPA on July 31, 2006. U.S. EPA approved this requests on May 16, 2007 (72 FR 27640).

Ohio EPA is now requesting a revision to the maintenance plan to update mobile emission projections and conformity budgets based on emission rates generated from U.S. EPA’s latest mobile emissions model, the Motor Vehicle Emission Simulat ion (MOVES) 2010. In December 2009, MOVES replaced MOBILE6.2 as the U.S. EPA’s official emission factor model. The area is still attaining and maintaining the 1997 8-hour ozone standard and the point, area and non-road emissions have not changed significantly and did not need to be updated for this submittal.

A redline/strike-out version of the original document follows this synopsis and identifies all changes that were made to the original approved request. In summary, revisions were made to the on-road (mobile) source emission estimates and budgets contained within the tables and text below. In addition, the discussion section regarding on-road modeling protocols was updated to identify the latest process applicable to the use of the newer MOVES model. Other minor changes were made to conform to current terminology, grammar, and formatting conventions.

In addition to this document, additional changes were also made to the Appendices of the original submittal, as follows:

Appendix C: this appendix contains the detailed modeling protocol used to generate on-road mobile source emission estimates. The document contained within this revised submittal is an entirely new document compared to the original modeling protocol document submitted in 2006. Both the original and revised documents are available on Ohio EPA’s website under the “Appendix” link. Appendix D: this appendix contains documents relevant to the public comment period and the public hearing. This will contain a revised public notice and revised hearing transcript. In some cases, if comments are received or testimony provided, it will also contain a revised response to comments document. Both the original and revised documents are available on Ohio EPA’s website under the “Appendix” link.

These draft documents can all be found at: http://www.epa.ohio.gov/dapc/SIP/1997.aspx in the table under the heading “Redesignations and Maintenance Plans.” The public comment period is open until March 4, 2013. Please refer to the Public Notice for how to

submit comments.

# REQUEST FOR REDESIGNATION AND

MAINTENANCE PLAN FOR
OZONE ATTAINMENT

IN THE OHIO
PORTION OF THE STEUBENVILLEWEIRTON

, OH

- WV
EIGHT-HOUR OZONE BASIC
NONATTAINMENT AREA

Jefferson County

, Ohio

(Steubenville-Weirton, OH-WV: Jefferson County)



# Developed By: Ohio Environmental Protection Agency
Division of Air Pollution Control in collaboration with West Virginia Department of Environmental

Protection

# July 2006

Revised March 2013 1

1 Revised- to update the on-road (highway) emission estimates and Jefferson County (OH) Motor Vehicle Emission Budgets (MVEBs) using the most recent U.S.EPA approved software, MOVES(2010). Formatted: Font: 20 ptThis page left intentionally blanki 

### TABLE OF CONTENTS

Chapter One

Introduction

..................................................................................................................................... 1 Background

..................................................................................................................................... 1 Geographical description

................................................................................................................ 2 Status of air quality

.......................................................................................................................... 2

Chapter Two Requirements for redesignation

...................................................................................................... 3

Chapter Three Ozone monitoring

............................................................................................................................ 6 Ambient data quality assured

.......................................................................................................... 7 Three complete years of data

......................................................................................................... 7 Commitment to continue monitoring

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

Chapter Four Emission Inventory

........................................................................................................................ 10 Base Year Inventory

...................................................................................................................... 10 Emission Projections

..................................................................................................................... 11
Demonstration of Maintenance

..................................................................................................... 16
Permanent and Enforceable Emissions Reductions

................................................................ 2122 Provisions for Future Updates

.................................................................................................. 2223

Chapter Five Control measures and regulations

............................................................................................ 2324 Implementation of Past SIP Revisions

..................................................................................... 2324
New Source Review Provisions

............................................................................................... 2526

As surance of continued controls

.............................................................................................. 2526

Chapter Six Contingency measures

............................................................................................................. 2728 Commitment to revise plan

....................................................................................................... 2728
Commi tm ent for contingency measures

................................................................................... 2728 Potential contingency measures

............................................................................................... 2829
List of VOC and NO

x

sources

................................................................................................... 2930

Chapter Seven Public participation

.................................................................................................................... 3132

Chapter Eight
Conclusions

............................................................................................................................... 3133ii FIGURES

Figure 1 Steubenville-Weirton, OH-WV: Jefferson County Basic Nonattainment Area

....... 6

TABLES

Table 1 Monitoring Data for Steubenville-Weirton, OH-WV: Jefferson Co. 2002

– 2004

... 8

Table 2 Monitoring Data for Wheeling, WV-OH: Jefferson County 2003 - 2005

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

Table 3 Emission Estimations for On-road Mobile Sources for Jefferson Co. OH

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

Table 4 Emission Estimations for On-road Mobile Sources for Brooke Co. WV

.............. 14
Table 5 Emission Estimations for On-road Mobile Sources for Hancock Co. WV

............ 14
Table 6 Combined Emission Estimations for On-road Mobile Sources

............................ 15 Table 7 Mobile Vehicle Emission Budgets

......................................................................... 15 Table 8 VOC Emission Inventory Jefferson Co. OH

...................................................... 1617 Table 9 VOC Emission Inventory Combined Hancock and Brooke Co. WV

................ 17 18 Table 10 VOC Emission Inventory Steubenville-Weirton, OH-WV: Jefferson Co.

TotalCombined Totals

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

Table 11 NO

x

Emission Inventory Jefferson Co. Ohio

..................................................... 1819

Table 12 NO

x

Emission Inventory Combined Hancock and Brooke Co. WV

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

Table 13 NO

x

Emission Inventory Steubenville-Weirton, OH-WV: Jefferson CoCombined

Totals 20 Table 14 Projected emission estimates 2004 -2018 Jefferson Co. Ohio

............................. 20 Table 15 Projected emission estimates 2004- 2018 Combined Hancock/ Brooke Co. WV 2021 Table 16 Projected emission estimates 2004- 2018 Combined VOC/NOx Totals

............... 21 Table 17 Combined comparison of 2002 and 2004 On-road and EGU Totals

............... 22 23

APPENDICES

A Aerometric Information Retrieval System (AIRS) Data

B Emission Inventories C Emissions Analysis Method D Public Participation Documentationiii This page left intentionally blank1 REQUEST FOR REDESIGNATION AND

MAINTENANCE PLAN FOR OZONE ATTAINMENT

IN THE EIGHT-HOUR OZONE BASIC

NONATTAINMENT AREA

Steubenville-Weirton, OH-WV: Jefferson County



### CHAPTER ONE

Introduction The Clean Air Act (CAA) requires areas failing to meet the National Ambient Air Quality Standard (NAAQS) for ozone to develop State Implementation Plans (SIP’s) to expeditiously attain and maintain the standard. In 1997, the United States Environmental Protection Agency (U.S. EPA) revised the air quality standards for ozone replacing the 1979 one-hour standard with an eight-hour ozone standard set at 0.08 parts per million (ppm). The standard was challenged legally and upheld by the U.S. Supreme Court in February of 2001.

On April 15, 2004, U.S. EPA designated 134 nonattainment areas for the eight-hour ozone

sta ndard. Since that time, U.S. EPA has reclassified nine of the 134 original nonattainment areas to the next lower classification. Section 107(d)(3)(E) of the CAA allows states to request nonattainment areas be redesignated to attainment providing certain criteria are met. The following are the criteria that must be met in order for an area to be redesignated

from nonattainment to attainment:

i) A determination that the area has attained the eight- hour ozone standard. ii) An approved State Implementation Plan (SIP) for the area under Sectio n 110(k ). iii) A determination that the improvement in air quality is due to permanent and enforceable reductions in emissions resulting from implementation of the SIP and other federal requirements. iv) A fully approved maintenance plan under Section 175(A). v) A determination that all Section 110 and Part D requirements have been

met.

Background Jefferson County, Ohio, Hancock and Brooke Counties in WV form the SteubenvilleWeirton, OH-WV interstate nonattainment area and constitute the Steubenville, OH Metropolitan Statistical Area. As part of the 1990 CAA Amendments re-evaluation, Steubenville-Weirton, OH-WV: Jefferson County was designated as Unclassifiable/Attainment for the one-hour ozone standard pursuant to the CAA and therefore, has not previously been subject to nonattainment area rule-makings. As a result of the 2004 ozone designations, U.S. EPA designated Steubenville-Weirton, OH-WV: Jefferson County basic nonattainment and subject to the eight-hour ozone requirements,

in cluding development of a plan to reduce volatile organic compounds (VOCs) and oxides2

of nitrogen (NO
x ) emissions and a demonstration that the area will meet the federal eighthour air quality standard for ozone by June 2009.

This document is intended to s upport Ohio’s request that the Steubenville-Weirton, OHWV: Jefferson County area be redesignated from nonattainment to attainment for the eight-hour ozone s ta ndard. Steubenville-Weirton, OH-WV: Jefferson County has recorded three (3) years of complete, quality-assured ambient air quality monitoring data for the

years 2002

– 2004 dem onstrating attainment of the eight-hour ozone standard.

Geographical Description Jefferson County is located in eastern Ohio and contains the city of Steubenville. Jefferson County is bordered by Columbiana County to the north, Jefferson to the south, Caroll and Harrison to the west and Hancock, Brooke and Ohio Counties in West Virginia to the east. This area is shown is shown in Figure 1

.

Status of Air Quality

Oz one monitoring data for the most recent three (3) years, 2002 through 2004

, demonstrates that the air quality has met the NAAQS for ozone in this b as ic nonattainment area. The NAAQS attainment, accompanied by decreases in emission levels discussed in Chapter four, supports a redesignation to attainment for Steubenville-Weirton, OH-WV: Jefferson County based on requirements in Section 107(d)(3)(E) of the CAA.3



### CHAPTER TWO

Requirements for Redesignation U.S. EPA has published detailed guidance in a document entitled Procedures for Processing Requests to Redesignate Areas to Attainment (redesignation guidance ), issued September 4, 1992, to Regional Air Directors. This request for redesignation and maintenance plan is based on the redesignation guidance, supplemented with additional guidance received from staff of U.S. EPA Region V.

Below is a summary of each redesignation criterion as it applies to SteubenvilleWeirton, OH-WV: Jefferson County.

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

The second component relies upon supplemental U.S. EPA-approved air quality modeling. The supplemental modeling is not required for ozone nonattainment areas seeking redesignation. Therefore, this ozone redesignation request for Steubenville-Weirton, OH-WV: Jefferson County does not include modeling data. However, in Appendix C the most recent modeling results showing future attainment and maintenance are provided. Chapter three discusses this requirement in more detail and provides the

attainment demonstration.

ii.) SIP approval: The SIP for the area must be fully approved under Section 110(k) and must satisfy all requirements that apply to the area. Ohio’s SIP was approved on May 9, 1994 (59FR23799) March 23, 1995 (60FR15235) and includes Steubenville-Weirton, OH-WV: Jefferson County. Chapter five discusses this requirement in more detail and provides the attainment demonstration.

iii.) Permanent and enforceable improvement in air quality; The state must be able to reasonably attribute the improvement in air quality to emission reductions which are permanent and enforceable. The state should estimate the percent reduction achieved from federal measures as well as control measures that have been adopted and implemented by the

state.4

Steubenville-Weirton, OH-WV: Jefferson County was not designatednonattainment for ozone as part of the 1990 CAA Amendments reevaluation. As a result, Ohio has not adopted or implemented control measures beyond the federal measures, the initial 1979 statewide rules and

those 1994 and 1995 rules whic h applied to “rural” attainment areas. Chapters four and five discuss this requirement in more detail and provide

the attainment demonstration.

iv.) Section 110 and Part D requirements: For purposes of redesignation, a state must meet all requirements of Section 110 and part D that were applicable prior to submittal of the complete redesignation request.

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

i.) Section 172(c) requirements This section contains general requirements for nonattainment plans.

The requirements for reasonable further progress, identification of certain emissions increases, and other measures needed for attainment will not apply for redesignations because they only have meaning for areas not attaining the standard. The requirements for an emission inventory will be satisfied by the inventory requirements of the maintenance plan.

ii.) Conformity The state must work with U.S. EPA to show that its SIP provisions are

consistent with section 176(c)(4) conformity requirements. The redesignation request should include conformity procedures, if the state already has these procedures in place. If a state does not have conformity procedures in place at the time that it submits a redesignation request, the state must commit to follow U.S. EPA ’s conformity regulation upon issuance, as applicable. Chapter five discusses this requirement in more detail and provides the attainment

demonstration.

v.) Maintenance plans. Section 107(d)(3)(E) stipulates that for an area to be redesignated, U.S. EPA must fully approve a maintenance plan which meets the requirements of Section 175(A). The maintenance plan will constitute a SIP revision and must provide fo r maintenance 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.5

In addition, the maintenance plan shall contain such contingency measures as the Administrator deems necessary to ensure prompt correction of any violation of the NAAQS. At a minimum, the contingency measures must include a requirement that the state will implement all measures contained in the nonattainment SIP prior to redesignation.

States seeking redesignation of a nonattainment area should consider the following provisions:

a.) attainment inventory; b.) maintenance demonstration; c.) monitoring network; d.) verification of continued attainment; and e.) contingency plan.

Chapter six discusses this requirement in more detail and provides the

attainment demonstration.6



### CHAPTER THREE

OZONE MONITORING CAA Section107 (d)(3)(E)(i)

Requirement 1 of 4 : A demonstration that the NAAQS for ozone, as published in 40 CFR 50.4, has been attained. Ozone monitoring data must show that violations of the ambient standard are no longer occurring.

Background : There are two monitors measuring ozone concentrations in this

no nattainment area. The primary monitor is located in Steubenville, Ohio and

is operated by O hio EPA’s Southeast District Office, Division of Air Pollution
Control. Data from a monitor located in Weirton

, West Virginia is also included for the eight-hour ozone attainment demonstration. The Weirton monitor is operated by the West Virginia Department of Environmental Protection (DEP), Division of Air Quality (DAQ), Northern Panhandle Regional Office. A listing of the four (4) highest readings from 2002 through

2004 is shown in Table 1 and readings from 2003-2005 are shown in Table 2. These readings were retrieved from the U.S. EPA air quality system ( AQS. ) The locations of the monitoring sites for this nonattainment area are shown on Figure 1.

Demonstration :

Figure 1 Steubenville-Weirton, OH-WV: Jefferson County Basic Formatted: Centered7 Nonattainment Area

Requirement 2 of 4 : Ambient monitoring data quality assured in accordance with 40 CFR 58.10, recorded in the U.S. EPA air quality system (AQS) database, and available for public view.

Demonstration : Ohio EPA and WV DEP have quality assu re d all data shown in Appendix A
in accordance with 40 CFR 58.10 and all other federal requirements. Ohio

EPA and WV DEP have recorded the data in the AQS database an d therefore data are available to the public.

Requirement 3 of 4 : A showing that the three-year average of the fourth highest values, based on data from all monitoring sites in the area or its affected downwind environs, are below 85 parts per billion (ppb). This showing must rely on three (3) complete, consecutive calendar years of quality assured data.

Background : The following information is taken from U.S. EPA's "Guideline on Data Handling Conventions for the eight- hour Oz one National Ambient Air Quality Standard (NAAQS)," U.S. EPA-454/R- 98 -017, December 1998.

Three (3) complete years of ozone monitoring data are required to demonstrate attainment at a monitoring site. The eight- hour primary and secondary ozone ambient air quality standards are met at an ambient airquality monitoring site when the three-year average of the annual fourthhighest daily maximum eight- hour average ozone concentration is less than or equal to 0.08 ppm. When this occurs, the site is said to be in attainment.8

Three (3) significant digits must be carried in the computations. Because the third decimal digit, in ppm, is rounded, 0.084 ppm is the largest concentration that is less than or equal to 0.08 ppm. Therefore, for the purposes of this request, the eight-hour standard is considered to be 0.085 ppm. Values

below 0.085 ppm meet the standard, values equal to or greater than 0.085 ppm exceed the standard. These data handling procedures are applied on an individual basis at each monitor in the area. An area is in compliance with the eight- hour

ozone NAAQS if, and only if, every monitoring site in the area meets the NAAQS. An individual site's three (3) year average of the annual fourth highest daily maximum eight- hour average ozone concentration is also called the site's design value. Table 1 shows the monitoring data for 2002

– 2004 and Table 2 show the monitoring data for 2003- 2005 at the
nonattainment area sites and was retrieved from the U.S. EPA AQS. The air quality design value for the area is the highest design value among all sites

in the area.

Demonstration :

Table 1 Monitoring Data for Steubenville-Weirton, OH-WV: Jefferson County 2002

– 2004

Data source: U. S. EPA Air Quality System (AQS)

http://www.epa.gov/ttn/airs/airsaqs/index.htm

1 st 2 nd 3 rd 4 th 2002

- 2004

AVERAGE SITE ID COUNTY ADDRESS YEAR %OBS 8

- HR 8

- HR 8

- HR 8

- HR

39

- 081

- 0016 JEFFERSON 227 NORTH 5 TH 2002 100 .099 .099 .093 .093 .081

39

- 081

- 0016 JEFFERSON 227 NORTH 5 TH 2003 99 .107 .097 .090 .079

39

- 081

- 0017 JEFFERSON 618 LOGAN 2004 99 .087 .075 .074 .071

54

- 029

- 1004 HANCOCK (WV) OAK ST & OWIN 2002 99 .099 .097 .097 .097 .078

54

- 029

- 1004 HANCOCK (WV) OAK ST & OWIN 2003 100 .111 .097 .085 .076

54

- 029

- 1004 HANCOCK (WV) OAK ST & OWIN 2004 100 .076 .072 .067 .063 Highest Average .081 ppm

Table 2 Monitoring Data for Steubenville-Weirton, OH-WV: Jefferson County 2003

– 2005
Data source: U.S. EPA Air Quality System (AQS)

http://www.epa.gov/ttn/airs/airsaqs/index.htm

1 st 2 nd 3 rd 4 th 2003

- 2005

AVERAGE SITE ID COUNTY ADDRESS YEAR %OBS 8

- HR 8

- HR 8

- HR 8

- HR

39

- 081

- 0016 JEFFERSON 227 NORTH 5 TH 2003 99 .107 .097 .090 .079 .077

39

- 081

- 0016 JEFFERSON 227 NORTH 5 TH 2004 99 .087 .075 .074 .071

39

- 081

- 0017 JEFFERSON 618 LOGAN 2005 100 .094 .092 .087 .083

54

- 029

- 1004 HANCOCK (WV) OAK ST & OWIN 2003 100 .100 .092 .083 .077 .075

54

- 029

- 1004 HANCOCK (WV) OAK ST & OW IN 2004 97 .079 .074 .074 .073

54

- 029

- 1004 HANCOCK (WV) OAK ST & OWIN 2005 100 .084 .084 .077 .075 Highest Average 0.77 ppm Formatted Table

Formatted Table9

A compr ehensive list of the site’s design values during the 2002

- 2004 time period is in Appendix A. The area's design value has trended downward as

emissions have declined due to such factors as cleaner automobiles and fuels both regionally and locally. U.S. EPA ’s rule to control nitrogen oxides from specific source categories (40 CFR Parts 51, 72, 75 and 96, published on October 17, 1998 and referred to as the NO
x SIP Call) has significantly reduced emissions from large electric generating units (EGUs), industrial boilers, and cement kilns. Ohio's NO
x Budget Trading Program Rule was approved on May 25, 2004 Ohio Administrative Code (OAC) Chapter 37 45

- 14 . It is expected that this downward trend will continue as the above programs continue and some form of the U.S. EPA Clean Air Interstate Rule (CAIR) is implemented.

Requirement 4 of 4 : A commitment that once redesignated, the state will continue to operate an appropriate monitoring network to verify the maintenance of the attainment status.

Demonstration : Ohio EPA and WV DEP commit to continue monitoring ozone levels at the sites indicated in Figure 1. Ohio EPA and WV D EP will consult with U.S.

EPA Region 5 and Region 3 prior to making changes to the existing monitoring network, should changes become necessary in the future. Ohio

EPA and WV DEP will continue to quality assure the monitoring data to meet the requirements of 40 CFR 58 and all other federal requirements. Connection to a central station and updates to the Ohio EPA W eb site 2 will provide real time availability of the data and knowledge of any exceedances. Ohio EPA and WV DEP will enter all data into AQS on a timely basis in accordance with federal guidelines.

2 www .epa.state.oh.us/dapc/10



### CHAPTER FOUR

EMISSION INVENTORY
CAA Section 107 (d)(3)(E)(iii)

U.S. EPA ’s redesignation g uidance requires the submittal of a comprehensive inventory of ozone precursor emissions (VOC and NO
x ) representative of the year when the area achieves attainment of the ozone air quality standard. Ohio also must demonstrate that the improvement in air quality between the year that violations occurred and the year that attainment was achieved is based on permanent and enforceable emission reductions

. Other emissions inventory related requirements include a projection of the emission inventory to a year at least 10 years following redesignation; a demonstration that the projected level of emissions is sufficient to maintain the ozone standard; and a commitment to provide future updates of the inventory to enable tracking of emission levels during the

10 year maintenance period.

Requirement 1 of 5 : A comprehensive emission inventory of the precursors of ozone completed for the base

year.

Background : The point source data are taken from Ohio's annual emissions reporting program. The 2002 periodic inventory has been identified as the preferred data base for SIP development and does coincide with nonattainment air quality in Steubenville-Weirton, OH-WV: Jefferson County.11

As part of the NO
x

SIP Call, the states were required to adopt into their rules a budget for all large EGUs. Ohio’s b udget is adopted at OAC Chapter

3745

- 14

. The budget represents a statewide cap on NO
x emissions. These emissions, capped by the state rule, should remain at least this low through the maintenance period covered by this request.

Periodic inventories, which include emissions from all sectors - mobile, area,

non -road, and point sources - are prepared every three (3) years.

Demonstration : While ozone and its precursors are transported into this region from outside areas, this information does provide some indication of the impact from Ohio sources near the nonattainment area. The emissions are decreasing substantially in response to regional and national programs affecting many EGUs such as the Acid Rain program and the NO
x SIP Call. Other sectors of the inventory also impact ozone formation, but large regional sources such as EGUs have a substantial impact on the formation of ozone.

Requirement 2 of 5 : A projection of the emission inventory to a year at least 10 years following redesignation.

Background : Ohio EPA prepared a comprehensive inventory for Steubenville-Weirton, OH-WV: Jefferson County, including area, mobile, and point sources for precursors of ozone (VOCs and NO
x ) for base year 2002. The information below describes the procedures Ohio EPA used to generate the 2002 base inventories. These inventories were provided to Lake Michigan Air Directors Consortium (LADCO) and have been processed to develop summer day emissions for use in the air quality analyses. These processed modeling inventories have been identified as the correct iteration of the inventory for use in the redesignation. In this document, references to LADCO include the Midwest Regional Planning Organization.

Area sources were taken from the Ohio 2002 periodic inventory submitted to U.S. EPA. These projections were made from the U.S. Department of Commerce Bureau of Economic Analysis (BEA) growth factors, with some updated local information.

Mobile source emissions were calculated from
MOBILE6.2MOVES2010 produced emission factors. Point source information was compiled from Ohio EPA’s 2002 annual emissions inventory database and the 2002 U.S. EPA Air Markets

acid rain database 3

.

3 http://www.epa.gov/airmarkets/acidrain12 Biogenic emissions are not included in these summaries. Non-road emissions were generated using U.S. EPA ’s National Mobile Inventory Model (NMIM) 2002 application. To address concerns about the accuracy of some of the categories in U.S. EPA ’s

non -road emissions model, LADCO contracted with two (2) companies to review the base data and make recommendations.One of the contractors also estimated emissions for three (3) nonroad categories not included in U.S. EPA ’s non -road model. Emissions were estimated for aircraft, commercial marine vessels and railroads. Recreational motorboat population and spatial surrogates (used to assign emissions to each county) were significantly updated. The populations for the construction equipment category were reviewed and updated based upon surveys completed in the Midwest and the temporal allocation for agricultural sources also was updated.

Demonstration :

On -Road Emission Estimations

In coordination with the Brooke, Hancock, Jefferson Transportation Study (BHJTS) and the West Virginia Department of Transportation (WVDOT), the Ohio Department of Transportation ( Ohio DOTODOT ) utilizes a regional

travel demand forecast model to simulate traffic in the area and to forecast traffic flows for given growth expectations. The model is primarily used as a long range planning tool to evaluate the transportation system including determination of locations where additional travel capacity may be needed and to determine the infrastructure requirements necessary to meet that need. It is also used as a tool for air quality purposes to estimate the total emissions of pollution caused by vehicles in the area. The travel demand

fo recasting model is used to predict the total daily vehicle miles traveled (VMT) and a U.S. EPA computer program called MOBILE6 .2 MOVES is used to calculate emissions per mile. The product of these is the total amount of pollution emitted by the on-road vehicles for the particular analyzed area. In areas outside the regional travel demand model, traffic counts and statewide traffic growth rates are used for the VMT estimates.

Overview

Broadly described, MOBILE6.2MOVES is used to generate “emission

factors ”, which are the average emissions per mile (grams/mile) for ozone Formatted: Normal, Indent: Left: 0", Right:

0.5"

Formatted: Line

spacing: Multiple 1.15 li

Formatted: Line

spacing: Multiple 1.15 li13

precursors, NOx and VOC. The MOBILE6 .2 MOVES model includes a

number of variables that affect the emission factors. These variables have national default values, some of which require modification to reasonably
reflect local conditions. Some of these variables are discussed here. The vehicle fleet (vehicles on the road) age and the vehicle type have a major

effect on the emission factors. The vehiclesource types are traveling on facilityroad types ( MOBILE6.2 facilityMOVES road types are Freeway, Arterial, LocalRural Restricted Access, Rural Unrestricted Access, Urban Restricted Access, and Ramp) and theUrban Unrestricted Access). The vehicle speeds also affect the emission factor values. Meteorological conditions such as air temperature and humidity has have a significant

affecteffect on emission factors. Emission factors produced by
MOBILE6MOVES can also include the effect of emission reduction strategies such as vehicle inspection and maintenance programs, regulation of fuels,

etc. These MOBILE6MOVES inputs are estimated using the best available

data.

These inputs are reviewed and agreed to by U.S. EPA and transportation agencies in a formal interagency consultation process. Emission factors are multiplied by VMT from the travel demand model to estimate the total vehicle

emissions.

There are a number of ways emission factors from MOBILE6.2 can be used with the travel demand model information. One of the simplest methods is to input extensive vehicle fleet, area-specific speed and facility type information MOBILE6.2 to generate a single emission factor that represents the average for all vehicles and facility types in the modeled area. This only requires multiplying this emission factor by the total VMT of the analyzed area to get

the total emissions for the area. Another method is to create multidimensional emission factor “look

- up” tables that describe the emission factors by speed, temperature, and facility type. This requires more extensive processing, but the resulting total emissions of this method are more sensitive to even minor changes in the roadway system. Tables of emission factors are created using MOBILE6.2 for each facility type, temperature, and speed given the vehicle fleet on that facility. Then, the travel model provides information on each segment of road (or “link”) regarding speed and facility type which is then “looked

- up” in the appropriate emission factor table. It should be noted that speed is estimated as a post process to the travel demand model. Speeds are not taken directly from the travel demand model. The post process for emissions analysis by Ohio DOT is by hour of day. This emission factor is multiplied by the link’s traffic

volume and length or VMT to get the emissions from that link for that hour. There are other methods as well, each with its advantages and disadvantages. The Steubenville-Weirton, WV-OH: Jefferson County analysis uses the latter more complex method, a table of emission factors. Formatted: Not Superscript/ Subscript

Formatted: Right: 0.5"14

It should be noted that each year analyzed will have different emission factors, volumes, speeds and roadway networks.

Some of the assumptions built into MOBILE6 .2 are: older vehicles have much higherThe emission factors from MOVES can be used with the travel demand model information by combining the disaggregate emission rates with VMT, and source type population for each road type, source type and hour of day, and then sum them up to get the total emissions for the area.

The BHJ TS analysis method, developed by ODOT, is to aggregate the emission rates by two source types (cars & trucks), then applying VMT and source type population, thereby reducing the intensive processes. In the first step emission factors are broadly classified into total vehicles, cars and trucks by pollutant, by average speed, road type and hour of day. Then the hourly link volumes generated from travel demand model are combined with

emission factors for each network link for each hour. The on-road vehicle

emissions for the area are the sum of all individual link-hour emissions. Vehicle-based emissions are obtained by the combination of corresponding emission factors and source type population. Intrazonal emissions are computed using a separate method to account for those trips that use local roads to travel within a zone. Intrazonal VMT is combined with correspondingemission factors to get intrazonal emissions. Total emissions are sum of onroad vehicle emissions, vehicle-based emissions and intrazonal emissions.

Automated programs, using FORTRAN and CUBE scripting, were developed by ODOT to generate total emissions. The process uses data on daily and directional traffic distributions as well as more up to date volume/delay functions from the 2000 Highway Capacity Manual (HCM). This process also handles the newer model network formats and MOVES generated emission

factors than newer vehicles, diesel vehicles have much higher NO
x emission factors and lower VOC emission factors than gasoline vehicles, and higher average speeds have lower emission factors except for diesel vehicles which have higher NO
x

at higher speeds. MOBILE6.2.

MOVES input and output files are provided in Appendix C.

Best Available Data

Most current vehicle age distribution data, temperature data, and fuel properties data , source type distribution data, and I/M data provided by ODOT’s ATRs and WIMs, NOAA, ODPS, and Ohio EPA waswere used by

the Ohio DOTODOT for generating emission factors. Likewise, the most current transportation planning data available from BHJ TS and most current
Ohio DOTODOT count data waswere used by the Ohio DOTODOT for the Formatted: Line spacing: Multiple 1.15 li

Formatted: No

widow/orphan control15

emissions estimates . Details about each data set and how it was used is
documented in Ohio DOT’s “ BHJTS 8-Hour Ozone Air Quality Conformity

Ana lysis Technical Memo” dated 6/29/ 2006

.

Analysis Years

Analysis years for this re-designation request include 2002, 2004, 2009, and 2018 to meet the requirements specified by the CAA and U.S. EPA. The travel demand model presents the transportation system conditions for each of these years. Model runs for each future analysis year contain the road

network BHJ TS and Ohio DOTODOT expects to exist at the beginning of that year with corresponding socioeconomic forecasts for that year.

Local Road VMT

Most local roads such as subdivision streets are not explicitly modeled in a
travel demand model. These local roads are represented as fictitious
roadways called centroid connectors. Local road VMT is included in the

Ohio DOTODOT post process by including the traffic loaded on centroid
connectors. In addition, some local road traffic is captured as intra-zonal
trips which travel demand models usually do not assign to roadway

segments. Ohio DOTODOT post process includes these trips as local road

VMT.

Emission Estimations Tables 3 through 5 contain the results of the emissions analysis for the appropriate years.

Table 3 - Emission Estimations for On-Road Mobile Sources for Jefferson County, Ohio
Jefferson County 2002 2004 2009 2018

VMT (miles/day) 1, 871,330 709,44

8 1, 871,278 611 ,12

5 1, 875,362 576,63

5 1, 882,256 540,06

0
VOC (tons/day) 4.22 6.61 3.55 5.62 2.29 4.20 1. 19 86

NOx (tons/day) 6.28 7.75 5.40 6.69 3.57 5.14 1.45 2.11

Table 4 - Emission Estimations for On-Road Mobile Sources for Brooke County, West Virginia
Brooke County 2002 200 4 2009 2018

VMT (miles/day) 669,015 606,19

5 662,880 600,70

2 696,616 602,92

8 710,506 600,94

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VOC (tons/day) 1. 59 40 1. 28 20 0. 85 83 0. 45 36

NOx (tons/day) 2. 16 21 1. 82 86 1. 27 28 0. 53 48

Table 5 - Emission Estimations for On-Road Mobile Sources for Hancock County, West Virginia
Hancock County 2002 2004 2009 2018

VMT (miles/day) 676,843 561,34

9 674,274 502,23

9 664,931 497,99

1 657,671 495,32

7
VOC (tons/day) 1. 63 08 1.34 0.88 0. 84 58 0. 43 25

NOx (tons/day) 2. 13 02 1. 81 56 1. 81 05 0. 49 37

Table 6 Combined VOC and NO
x Emission Estimations for On-Road

Mobile Sources for Jefferson County, OH, Brooke and Hancock County, WV

Data source: On -road only, Ohio DOT Modeling and Forecasting Section.

County VOC 2018
Jefferson County, OH VOC 1. 19 86

Brooke County, WV VOC 0. 45 36

Hanc ock County, WV VOC 0. 43 25

TOTAL VOC 2. 07 47

County NO
x Jefferson County, OH NO
x 1.45 2.11

Brooke County, WV NO
x 0. 45 48

Hancock County, WV NO
x 0. 49 37

TOTAL NO
x 2. 39 96

Motor Vehicle Emission Budget

Table 7 contains the motor vehicle emissions budget for Jefferson County, Ohio. Formatted: Font color: Black

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Table 7 Mobile Vehicle Emissions Budget for Jefferson County, Ohio (Steubenville-Weirton, OH_WV) 4

Jefferson County 2004 2009 2018 VOC (tons/day) 5.62 4.83 2. 63 14 1.3

7
NO
x (tons/day) 4.10 6.6

9 1.67 5.91 2.43

Brooke and Hancock Co. 2009 2018 VOC (tons/day) 1.9

6 2. 82 60 3.40 1.90

NO
x (tons/day) 1.00 3.6

0 1.17 4.20 3.90

This Th e Jefferson County budget includes the emission estimates calculated

for 2009 and 2018 and an additional margin of safety. The emission estimates are derived from the Tranplan travel demand model and
MOBILE6 .2 MOVES 2010 as described above under the expected Brooke, Hancock, and Jefferson Transportation Study (BHJTS) 2025 Long Range Plan. The mobile source budget includes 1.374.83 tons/day for VOC and 1.67in 2009, 2.14 tons/day for VOC in 2018, 5.91 tons/day for NO
x . in 2009

, and 2.43 tons/day for NO
x in 2018. These correspond to a 15 percent

increase from the 2018 on -road emissions for both VOC and NO
x . Ap pen dix
C contains data tables and graphs of these emissions. Tables 10 and 8 through 13 below include the mobile vehicle emission budgets.

All methodologies, latest planning assumptions and the safety margins were determined through the interagency consultation process described in the Transportation Conformity Memorandum of Understanding (MOU) for
BHJTS.

Requirement 3 of 5 : A demonstration that the projected level of emissions is sufficient to maintain the ozone

standard.

4 Ohio’s submittal only requests bud gets be set for Ohio counties. Current 2004, 2009 and 2018 budgets for West Virginia are identified in Table 7 and subsequent tables. These budgets were set by West Virginia to address the transition to MOVES and U.S. EPA approved these budgets on September 15, 2011 (76 FR 56975). West Virginia does not plan to make any further updates to their ozone budgets). Formatted Table

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+ 2", Left

+ 2.5", Left + 3", Left

+ 3.5", Left

+ 4", Left

+ 4.5", Left + 5", Left

+ 5.5", Left

+ 6", Left18

Background : In consultation with U.S. EPA, Ohio EPA selected the year 2018 as the maintenance year for this redesignation request. This document contains projected emissions inventories for 2009 and 2018.

Ohio DOT performed emission projections for Steubenville-Weirton, OH-WV: Jefferson County using the following approaches.

Mobile source emission projections are based on the U.S. EPA
MOBILE6 .2 model.MOVES 2010model. The analysis is described in more detail in Appendix C. All projections were made in accordance

with “Procedures for

P reparing Emissions Projections” U.S. EPA-45/4-

91 -019.

Emissions inventories are required to be projected to future dates to assess the influence growth and future controls will have. LADCO has developed growth and control files for point, area, and n on -road categories. These files were used to develop the future year

emissions estimates used in this document. This was done so the inventories used for redesignation are consistent with modeling performed in the future.

The detailed inventory information for Jefferson County for 2004, 2009 and 2018 is in Appendix B. Emission trends are an important gauge for continued compliance with the ozone standard. Therefore, Ohio EPA performed an initial comparison of the inventories for the base year and maintenance years. Mobile source emission inventories are described in Appendix BC . In addition to the LADCO estimates, point source emissions were projected based upon the statewide EGU NO
x budgets from the Ohio
NO
x rule. Emission Inventories for Hancock and Brooke Counties in WV used for this request were developed by DEP staff with the support of the contractors for the Visibility Improvement State and Tribal Association of the Southeast (VISTAS), a federally recognized regional planning organization.

The following tables include sectors Electrical Generating Unit (EGU-Point), Non-Electrical Generating Unit (Non-EGU), Non-road Mobile (Non-road), Other Area (Other), Marine, Aircraft, Rail (MAR), On-road Mobile (On-road).

Please note that WV non-road sector includes MAR.

Demonstration :

Table 8 Jefferson County VOC Emission Inventory Totals for Base

Year 2002 , Estimated 2004 and Projected 2009 and 2018 (tons per day)19

Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air Directors Consortium (LADCO) Web site: http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm

. Data source: On -road only, Ohio DOT Modeling and Forecasting Section.

Sector 2002

Base 2004

Attainment 2009

Interim 2018

Maintenance Safety

Margin

EGU Point 0.88 0.92 1.03 1.02

Non

- EGU 0.23 0.23 0.22 0.24

Non

- road 0.90 0.88 0.82 0.55

Other 3.12 3.06 2.91 2.91

M AR 0.05 0.05 0.05 0.05

On

- road 4.22 6.61 3.55 5.62 2. 63 4.83

* 1.37 2.14 *

TOTAL 9.40 11.7

9 8.69 10.76 7.66 9.86 6. 14 91 2.55 3.8

5 * includes 15 percent increase to the mobile source budget

Table 9 Combined Hancock and Brooke County VOC Emission Inventory Totals for Base Year 2002 , Estimated 2004 and Projected 2009 and 2018 (tons per day)

Data source: WV emission inventory, Visibility Improvement State and Tribal Association of the Southeast (VISTAS) http://www.vistas-sesarm.org/

. Data source: On -road only, Ohio DOT Modeling and Forecasting Section.

Sector 2002

Base 2004

Attainment 2009

Interim 2018

Maintenan ce Safety

Margin

EGU Point n/a n/a n/a n/a

Non

- EGU 6.70 4.80 4.30 5.30

Non

- road

(includes MAR) 1.50 1.50 1.20 1.00

Other (Area ) 4.50 4.60 4.50 5.20 Formatted Table

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On

- road 3.20 2.4

8 2.60 2.00* 3.40 1. 00* 90

TOTAL 15. 90 18 13.50 12.00 13.4

0 12.50 13.40 1.00 0.1

0 * includes 15 percent increase to the mobile source budget

Table 10 Steubenville-Weirton, OH-WV: Jefferson CountyCombined

VOC Emission Inventory Totals for Base Year 2002 , Estimated 2004

and Projected 2009 and 2018 (tons per day)

Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air Directors Consortium (LADCO) Web site: http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm

. Data source: WV emission inventory, Visibility Improvement State and Tribal Association of the

Southeast (VISTAS) http://www.vistas-sesarm.org/

. Data source: On -road only, Ohio DOT Modeling and Forecasting Section.

2002

Base 2004

Attainment 2009

Interim 2018

Maintenance Safety

Margin

Jefferson Co. OH

Total 9.40 1

1.79 8.69 10.76 7.66 9.8

6 6. 14 91

B rooke and Hancock

Co. WV Total 15. 90

18 13.50 12.00 1

3.40 12.50 13.40

COMBINED VOC

TOTAL 25.30

26.97 22.19 24.26 19.66 2

3.26 18.64 20.31 3. 55 95

Table 11 Jefferson County NO
x Emission Inventory Totals for Base Year

2002

, Estimated 2004 and Projected 2009 and 2018 (tons per day)

Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air Directors Consortium (LADCO) Web site: http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm

. Data source: On -road only, Ohio DOT Modeling and Forecasting Section.

Sector 2002 Base 2004

Attainment 2009

Interim 2018

Maintenance Safety

Margin

EGU Point 183.99 148.80 60.77 40.95

Non

- EGU 6.05 5.93 5.63 5.43 Formatted: Font color: Black

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Non

- road 0.77 0.72 0.58 0.33

Other 0.17 0.18 0.21 0.21

M AR 1.60 1.53 1.35 1.25

On

- road 6.28 7.75 5.40 6.69 4.10 5.91 * 1.67 2.43 *

TOTAL 198.86 200.3

3 162.56 163.8

5 72.64 74.4

5 49.84 50.60 112.72 113.2

5 * includes 15 percent increase to the mobile source budget

Table 12 Combined Hancock and Brooke County NO
x Emission Inventory Totals for Base Year 2002

, Estimated 2004 and Projected 2009 and 2018 (tons per day)

Data source: WV emission inventory, Visibility Improvement State and Tribal Association of the

Southeast (VISTAS) http://www.vistas-sesarm.org/

. Data source: On -road only, Ohio DOT Modeling and Forecasting Section.

Sector 2002

Base 2004

Attainment 2009

Interim 2018

Maintenance Safety

Margin

EGU Point n/a n/a n/a n/a

Non

- EGU 5.90 4.50 5.10 5.60

Non

- road (includes MAR) 4.30 5.30 3.80 3.20

Other (Area) 4.6 0 4.80 4.90 5.20

On

- road Hancock 4. 30 23 3.60 2.80* 4.20 1.20* 3.90

TOTAL 19. 10 0

3 18. 20 16.60 18.0

0 15.20 17.90 3.00 0.3

0 * includes 15 percent increase to the mobile source budget

Table 13 Steubenville-Weirton, OH-WV: Jefferson CountyCombined

NO
x Emission Inventory Totals for Base Year 2002 , Estimated 2004 and Projected 2009 and 2018 (tons per day)

Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air Directors Consortium (LADCO) Web site:

http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm

. Data source: WV emission inventory, Visibility Improvement State and Tribal Association of the

Southeast (VISTAS) http://www.vistas-sesarm.org/

. Data source: On -road only, Ohio DOT Modeling and Forecasting Section.

2002 2004 2009 2018 Safety Formatted: Font color: Black

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Jefferson Co. OH

Total 198.86

200.33 162.56 163.

85 72.64 7

4.45 49.84 50.60

Hancock and Brooke

Co. WV Total 19. 10 0

3 18 .20 16.60 1

8.00 15.20 17.90

COMBINED NO
x TOTAL 217.95

219.36 183.79 182.

05 88.36 9

2.45 64.64 68.50 119.15

113. 55

Table 14 Jefferson County Comparison of 2004 attainment year and 2018 projected emission estimates (tons per day, summer)

Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air Directors Consortium (LADCO) Web site:

http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm

. Data source: On -road only, Ohio DOT Modeling and Forecasting Section.

2004 2018 Projected

Decrease

VOC 8.69 10.76 6. 14 91 2.55 3.85

NO
x 162.56 163.85 49.84 50.60 112.74 113.25

Table 16 15 Combined Hancock and Brooke County Comparison of 2004

attainment year and 2018 projected emission estimates (tons per day, summer)

Data source: WV emission inventory, Visibility Improvement State and Tribal Association of the Southeast (VISTAS) http://www.vistas-sesarm.org/

. Data source: On -road only, Ohio DOT Modeling and Forecasting Section.

2004 2018 Projected

Decrease

VOC 13.50 12.50 13.40 0. 26 10

NO
x 19.10 18. 20 15.20 17.90 3.21 0.30 Formatted: Font color: Black

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Table 1716 Steubenville-Weirton, OH- WV : Jefferson County Combined Comparison of 2004 attainment year and 2018 projected emission estimates (tons per day, summer)

Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air Directors Consortium (LADCO) Web site:

http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm

. Data source: WV emission inventory, Visibility Improvement State and Tribal Association of the Southeast (VISTAS) http://www.vistas-sesarm.org/

. Data source: On -road only, Ohio DOT Modeling and Forecasting Section.

2004 2018 Projected

Decrease

Combined VOC Total 22.19 24.26 18.64 20.

31 3. 55 95

Combined NOx Total 181.66 182.

05 65.04 68.

50 116.62 113.55

VOC emissions in the non-attainment area are projected to decrease by

3. 5595 tons

. Area source emissions and, to a lesser extent, point sources, show an increase due to expectations that the population will grow in this area. However, cleaner vehicles and fuels are expected to be in place in 2009 and 2018 and result in an overall drop in VOC emissions.

NO
x emissions in the nonattainment area are projected to decrease by

116.62 113.55 tons. Decreases from U.S. EPA rules covering Tier 2 Motor Vehicle Emissions Standards and Gasoline Sulfur Control Requirements 5

, Highway Heavy-Duty Engine Rule 6 and Non- Ro ad Diesel Engine Rule 7 also are factored into the changes. Further, due to implementation of the NO
x SIP Call across the eastern United States, NO
x and ozone levels entering

this area also will be decreased.

Requirement 4 of 5 : A demonstration that improvement in air quality between the year violations occurred and attainment was achieved is based on permanent and enforceable emission reductions and not on temporary adverse economic conditions or unusually favorable meteorology.

Background :

5 http://www.epa.gov/fedrgstr/EPA-AIR/2000/February/Day-10/a19a.htm

6 http://www.epa.gov/fedrgstr/EPA-AIR/1997/October/Day-21/a27494.htm

7 http://www.epa.gov/fedrgstr/EPA-AIR/1998/October/Day-23/a24836.htm Formatted Table

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Ambient air quality data from all monitoring sites indicate that air quality met
the NAAQS for ozone in 2004 . U.S. EPA ’s redesignation g uidance (p 9) states, “A state may generally demonstrate maintenance of the NAAQS by either showing that future emissions of a pollutant or its precursors will not exceed the level of the attainment inventory, or by modeling to show that the

future mix of sources and emissions rates will not cause a violation of the
NAAQS.”

In Ohio, major point sources in all counties are required to submit air emissions information once every three (3) years or annually if VOC potential to emit is greater than 250 tons or NO
x potential to emit is greater than 2500

t ons, in accordance with U.S. EPA’s Consolidated Emissions Reporting Rule (CERR). Ohio U.S. EPA prepares a new periodic inventory for all ozone precursor emission sectors every three (3) years. These ozone precursor inventories will be prepared for 2005, 2008, and 2011 as necessary to comply with the inventory reporting requirements established in the CFR. Emissions information will be compared to the 2002 base year and the 2018 projected maintenance year inventories to assess emission trends, as necessary, to assure continued compliance with the ozone standard.

Demonstration : Permanent and enforceable reductions of volatile organic compounds and oxides of nitrogen have contributed to the attainment of the eight- hour ozone standard. Some of these reductions were due to the application of tighter federal standards on new vehicles. Also, Title IV of the CAA and the NO
x SIP Call required the reduction of oxides of nitrogen from utility sources.

Table 1817 Steubenville-Weirton, OH- WV : Jefferson County CombinedComparison of 2002 base year and 2004 attainment year onroad and EGU reductions

Data source: Midwest Regional Planning Organization (MRPO) and Lake Michigan Air Directors Consortium (LADCO) Web site:

http://www.ladco.org/tech/emis/basek/BaseK_Reports.htm

. Data source: WV emission inventory, Visibility Improvement State and Tribal Association of the

Southeast (VISTAS) http://www.vistas-sesarm.org/

. Data source: On -road only, Ohio DOT Modeling and Forecasting Section25 2002 2004

On

- road VOC 7.45 9.09 6.18 8.22

On

- road NO
x 10.57 11.98 9.03 10.29

EGU NO
x 183.99 148.80

Requirement 5 of 5 : Provisions for future annual updates of the inventory to enable tracking of the emission levels including an annual emission statement from major sources.

Demonstration : As required by Section 175A(b) of the CAA, Ohio commits to submit to the Administrator, eight (8) years after redesignation, an additional revision of this SIP. The revision will contain Ohio's plan for maintaining the national primary ozone air quality standard for 10 years beyond the first 10 year period after redesignation. Formatted Table26



### CHAPTER FIVE

CONTROL MEASURES AND REGULATIONS
CAA Section 107 d)(3)(E)(ii), 107(d)(3)(iv) & 107(d)(3)(E)(v)

Re quirement 1 of 4: A U.S. EPA approved SIP control strategy that includes Reasonably Available Control Technology (RACT) requirements for existing stationary sources covered by Control Technology Guidelines (CTG) as applied in Ohio’s rural counties.

Background : As required by Section 172 of the 1990 CAA Amendments, in the mid- 1990’s Ohio promulgated rule requiring RACT for emissions of VOCs. There were no specific rules required by the CAA such as RACT for existing sources beyond

statewide rules.

Demonstration : Statewide RACT rules have been applied to all new sources locating in Ohio since that time. The Ohio rules are found in OAC Chapter 3745- 21.

Requirement 2 of 4: Evidence that control measures required in past ozone SIP revisions have been fully implemented.

Background : The U.S. EPA NO
x

SIP Call required 22 states to pass rules that would result in significant emission reductions from large EGUs, industrial boilers, and cement kilns in the eastern United States. Ohio passed this rule in 2001.

Be ginning in 2004, this rule accounts for a reduction of approximately 31 percent of all NO
x

emissions state-wide compared to previous uncontrolled years. The other 21 states also have adopted these rules.

Demonstration : U.S. EPA and Ohio EPA performed modeling that indicated this area would attain the eight- hour

ozone standard with the implementation of the NO
x SIP Call. Controls for EGUs 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 U.S. EPA
Clean Air Markets W eb site, quantifies the gradual NO
x reductions that have
occurred in Ohio as a result of Title IV of the 1990 CAA Amendments and the beginning of the NO
x SIP Call Rule. Ohio developed the NO
x Budget Trading Program rules in OAC Chapter 3745-14 in response to the SIP Call. OAC chapter 3745-14 regulated EGUs and certain non -EGUs under a cap and trade program based on an 85 percent reduction of NOx emissions from27

EG Us and a 60 percent reduction of NO
x emissions from non-EGUs, compared to historical levels. This cap will stay in place through 2008, at which time the CAIR program will supersede it.

U.S. EPA has recently published Phase II of the NO
x SIP Call that establishes a budget for large (greater than 1 ton per day emissions) stationary internal combustion engines. Ohio EPA’s proposed rule OAC

3745

- 14 -12 addresses stationary internal combustion engines, all used in natural gas pipeline transmissions. An 82 percent NO
x reduction from 1995 levels is anticipated. Completion of the compliance plan is expected by May 1, 2006 and the compliance demonstration will begin May 1, 2007. The
2007 controlled NO
x emissions will be 599 tons per day.

Tier II Emission Standards for Vehicles and Gasoline Sulfur Standards In February 2000

, U.S. EPA finalized a federal rule to significantly reduce emissions from cars and light trucks, including sport utility vehicles (SUVs). Under this proposal, automakers will be required to sell cleaner cars, and refineries will be required to make cleaner, lower sulfur gasoline. This rule will apply nationwide. The federal rules will phase in between 2004 and
2009. U.S. EPA has estimated that NO
x emission reductions will be approximately 77 percent for passenger cars, 86 percent for smaller SUVs, light trucks, and minivans, and 65 to 95 percent reductions for larger SUVs, vans, and heavier trucks. VOC emission reductions will be approximately 12 percent for passenger cars, 18 percent for smaller SUVs, light trucks, and minivans, and 15 percent for larger SUVs, vans, and heavier trucks.

Heavy-Duty Diesel Engines In July 2000, U.S. EPA issued a final rule for Highway Heavy Duty Engines, a program which includes low-sulfur diesel fuel standards, which will be phased in from 2004 through 2007. This rule applies to heavy-duty gasoline and diesel trucks and buses. This rule will result in a 40 percent reduction in
NO
x from diesel trucks and buses, a large sector of the mobile sources NO
x inventory.

Clean Air Non-road Diesel Rule In May 2004, U.S. EPA issued the Clean Air Non-road Diesel Rule. This rule applies to diesel engines used in industries such as construction, agriculture, and mining. It also contains a cleaner fuel standard similar to the highway diesel program. The new standards will cut emissions from non-road diesel engines by more than 90 percent. 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 current levels, from

appr oximately 3,000 parts per million (ppm) now to 15 ppm in 2009. New engine standards take effect, based on engine horsepower, starting in 2008.28

Together, these rules will substantially reduce local and regional sources of

ozone precursors.

Requirement 3 of 4: Acceptable provisions to provide for new source review.

Background : Ohio has a long standing and fully implemented New Source Review (NSR) program. This is addressed in OAC Chapter 3745-31. The chapter includes provisions for the Prevention of Significant Deterioration (PSD) permitting program in OAC 3745- 31 -01 to 3745- 31 -20. Ohio's PSD program was

co nditionally approved on October 10, 2001 (66 FR 51570) and received final approval on January 22, 2003 (68FR 2909) by U.S. EPA as part of the
SIP.

Demonstration : Any facility that is not listed in the 2002 emission inventory, or for the closing of which credit was taken in demonstrating attainment, will not be allowed to construct, reopen, modify, or reconstruct without meeting all applicable permit rule requirement. The review process will be identical to that used for new sources. Once the area is redesignated, Ohio EPA will implement NSR through the PSD program.

Requirement 4 of 4: Assure that existing controls will remain in effect after redesignation unless the State demonstrates through photochemical modeling that the standard can be maintained without one (1) or more controls.

Demonstration : Ohio commits to maintaining the aforementioned control measures after redesignation. Ohio hereby commits that any changes to its rules or emission limits applicable to VOC and/or NO
x sources, as required for maintenance of the ozone standard in Steubenville-Weirton, OH-WV: Jefferson County, will be submitted to U.S. EPA for approval as a SIP

revision.

Ohio, through Ohio EPA’s Legal section, has the legal authority and necessary resources to actively enforce any violations of its rules or permit provisions. After redesignation, it intends to continue enforcing all rules that relate to the emission of ozone precursors in Steubenville-Weirton, OH-WV: Jefferson County.29

LADCO Modeling Analysis for 8-Hour Ozone Standard Assessment

LADCO performed modeling to evaluate the effect of the NO
x SIP Call and Tier II / Low Sulfur rule for future year 2007 ozone in the Lake Michigan area. This modeling was originally designed to assess the one-hour ozone standard. Further analysis was conducted and documented in the LADCO’s White Paper “8 -Hour Ozone Assessment” dated May 2, 2001. Base year design values used were the average of the design values for the three (3) three-year periods (1994-1996, 1995- 1997, and 1996 -1998). Base year emissions were taken from 1996 and four (4) ozone episodes were evaluated: June 22-28, 1991; July 14-21, 1991; June 13-25, 1995; and July 7-18, 1995.

While modeling results were not calculated for Steubenville-Weirton, OH-WV: Jefferson County, the average decrease in ozone from the base case modeling run with modeling runs that applied emission controls required by the CAA

, NO
x SIP Call and Tier II /low-sulfur requirements was nine (9) ppb.

LADCO Modeling for CAIR of 2004

On March 10, 2004 , the U.S. EPA promulgated the CAIR. NO
x emissions will 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 eastern states and the District of Columbia.

LADCO performed modeling to support the associated emission reductions for CAIR. This modeling was based on 2001

– 2002 design values for SteubenvilleWeirton, OH-WV: Jefferson County. Results of the CAIR modeling showSteubenville-Weirton, OH-WV: Jefferson County will continue to attain the eighthour ozone NAAQS well into the future.30



### CHAPTER SIX

CONTINGENCY MEASURES CAA Section 107(d)(3)(E)(v)

Requirement 1 of 4: A commitment to submit a revised plan eight (8) years after redesignation.

Demonstration : Ohio hereby commits to review its maintenance plan eight (8) years after redesignation, as required by Section 175(A) of the CAA

.

Requirement 2 of 4: A commitment to expeditiously enact and implement additional contingency control measures in response to exceeding specified predetermined levels (triggers) or in the

event that future violations of the ambient standards occur.

Demonstration : Ohio hereby commits to adopt and expeditiously implement necessary corrective actions in the following circumstances:

Warning Level Response: A warning level response shall be prompted whenever an annual (1-year) fourth high monitored value of 88 ppb occurs in a single ozone season within the maintenance area. A warning level response will consist of a study to determine whether the ozone value indicates a trend toward higher ozone values or whether emissions appear to be increasing. The study will evaluate whether the trend, if any, is likely to continue and, if so, the control measures necessary to reverse the trend taking into consideration ease and timing for implementation as well as economic and social considerations. Implementation of necessary controls in response to a warning level response trigger will take place as expeditiously as possible, but in no event

later than 12 months from the conclusion of the most recent ozone season (September 30).

Should it be determined through the warning level study that action is necessary to reverse the noted trend, the procedures for control selection

and implementation outlined under action level response shall be followed.

Action Level Response

An action level response shall be prompted whenever a two (2) year average fourth high monitored value of 85 ppb occurs within the maintenance area. In the event that the action level is triggered and is not due to an exceptional event, malfunction, or noncompliance with a permit condition or rule31

requirement, Ohio EPA will determine additional control measures needed to assure future attainment of NAAQS for ozone. In this case, measures that can be implemented in a short time will be selected in order to be in place within eighteen (18) months from the close of the ozone season that prompted the action level.

Control Measure Selection and Implementation

Adoption of any additional control measures is subject to the necessary administrative and legal process. This process will include publication of notices, an opportunity for public hearing, and other measures required by Ohio law for rulemaking by state environmental boards.

If a new measure/control is already promulgated and scheduled to be implemented at the federal or state level, and that measure/control is determined to be sufficient to address the upward trend in air quality, additional local measures may be unnecessary. Furthermore, Ohio will submit to U.S. EPA an analysis to demonstrate the proposed measures are adequate to return the area to attainment.

Requirement 3 of 4: A list of potential contingency measures that would be implemented in such an event.

Demonstration : Contingency measures to be considered will be selected from a comprehensive list of measures deemed appropriate and effective at the

time the selection is made. The selection of measures will be based on costeffectiveness, emission reduction potential, economic and social considerations or other factors that Ohio EPA deems appropriate. Ohio EPA will solicit input from all interested and affected persons in the maintenance area prior to selecting appropriate contingency measures. Because it is not possible at this time to determine what control measure will be appropriate at an unspecified time in the future, the list of contingency measures outlined below is not comprehensive.

1) Lower Reid vapor pressure gasoline program.

2) Tighten RACT on existing sources covered by U.S. EPA Control Technique Guidelines issued in response to the 1990 CAA.

3) Apply RACT to smaller existing sources.

4) One or more transportation control measures sufficient to achieve at

le ast half a percent reduction in actual area wide VOC emissions. Transportation measures will be selected from the following, based32 upon the factors listed above after consultation with affected local governments:

a) trip reduction programs, including, but not limited to, employerbased transportation management plans, area wide rideshare programs, work schedule changes, and telecommuting:

b) traffic flow and transit improvements:

c) other new or innovative transportation measures not yet in widespread use that affects state and local governments deemed appropriate.

5) Alternative fuel and diesel retrofit programs for fleet vehicle operations.

6) Controls on consumer products consistent with those adopted
elsewhere in the United States.

7) Require VOC or NO
x emission offsets for new and modified major

sources.

8) Require VOC or NO
x emission offsets for new and modified minor

sources.

9) Increase the ratio of emission offsets required for new sources.

10) Require VOC or NO
x controls on new minor sources (less than 100 tons).

No contingency measure shall be implemented without providing the opportunity for full public participation during which the relative costs and benefits of individual measures, at the time they are under consideration, can be fully evaluated.

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

sources potentially subject to future controls.

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

controls.

NO
x RACT

EGUs asphalt batching plants33

industrial/commercial and institutional boilers process heaters internal combustion engines

combustion turbines other sources greater than 100 tons per year

VOC RACT consumer products architectural and industrial maintenance coatings stage I gasoline dispensing facilities (including pressure valves) automobile refinishing shops cold cleaner degreasers portable fuel containers synthetic organic compound manufacturing organic compound batch processes wood manufacturing

industrial wastewater aerospace industry shipbuilding

bakeries plastic parts coating volatile organic liquid storage industrial solvent cleaning offset lithography industrial surface coating other sources greater than 50 tons per year34



### CHAPTER SEVEN

PUBLIC PARTICIPATION

Ohio published notification for a public hearing and solicitation for public comment concerning the draft redesignation petition and maintenance plan in the widely distributed county pub lications on August 1, 2006

.

The public hearing to receive comments on the redesignation request was held on September 7, 2006March 4, 2013 , at the Brooke-Hancock-Jefferson Metropolitan Planning CommissionSteubenville Schiappa Branch Library , located at 124 North
Fourth Street4141 Mall Drive

, in Steubenville, Ohio. The public comment period will

closeclosed on September 8, 2006

. Comments received during the public comment period will be included with the final package.March 4, 2013

. Appendix D will include a copy of the public notice, certifications of publicationresponse to comments , and the transcript from the public hearing. Formatted: Font: Calibri, 11 pt, Font color: Custom Color(RGB(31,73,125))35



### CHAPTER EIGHT

CONCLUSIONS

The Steubenville-Weirton, OH-WV: Jefferson County basic nonattainment area has attained the NAAQS standard and complied with the applicable provisions of the 1990 Amendments to the CAA regarding redesignations of basic ozone nonattainment areas. Documentation to that effect is contained herein. Ohio EPA has prepared a state implementation and maintenance plan that meets the requirement of Section 110 (a)(1) of
the 1990 CAA

.

Ohio has performed an analysis that shows the air quality improvements are due to permanent and enforceable measures. In addition, significant regional NO
x reductions will ensure continued compliance (maintenance) with the standard and that all CAA requirements necessary for redesignation have been met.

Based on this presentation, the Steubenville-Weirton, OH-WV: Jefferson County ozone basic nonattainment area meets the requirements for redesignation under the CAA and U.S. EPA guidance. Furthermore, because this area is subject to significant transport of pollutants, significant regional NO
x reductions will ensure continued compliance (maintenance) with the standards with an increasing margin of safety.

The State of Ohio hereby requests that the Steubenville-Weirton, OH-WV: Jefferson County ozone basic nonattainment area be redesignated to attainment simultaneously with U.S. EPA approval of the Ohio state implementation and maintenance plan provisions

contained herein. Formatted: Font: 14 pt, BoldThis page left intentionally blank

# B ROOKE 

# -H ANCOCK 

# - J EFFERSON



# T RANSPORTATION 

# S TUDY

Transportation Air Quality Analysis and Technical Documentation

For the Weirton-Steubenville, WV- OH

State Implementation Plan Inventory Mobile Emission Estimates

Using the USEPA Motor Vehicle Emissions Simulator Model

For the U.S. EPA Eight-Hour Ozone National Ambient Air Quality Standard

Submitted: December 2012

### Production of this Document paid for by funds from the U.S. Federal Highway Administration, Federal

Transit Administration, Ohio Department of Transportation, West Virginia Department of Transportation and dues from BHJ member governments.

Prepared By:

Brooke-Hancock-Jefferson Metropolitan Planning Commission The Metropolitan Planning Organization for Steubenville, Ohio-Weirton, WV Area 124 North Fourth Street, 2 nd 

### Floor Steubenville, OH 43952

740/282-3685

304/797-9666

740/282-1821 FAX

Email: mikepap@bhjmpc.org Website: www.bhjmpc.orgTransportation Air Quality Analysis And Technical Documentation Weirton-Steubenville

, WV

- OH State Implementation Plan MOVES Based Inventory for the U.S. EPA Eight-Hour Ozone Air Quality Standard

December 2012 Page i



### BROOKE-HANCOCK-JEFFERSON TRANSPORTATION STUDY

Transportation Air Quality Analysis and Technical Documentation

For the Weirton-Steubenville, WV- OH State Implementation Plan Inventory Mobile Emission Estimates Using the USEPA Motor Vehicle Emissions Simulator Model For the U.S. EPA Eight-Hour Ozone National Ambient Air Quality Standard

TABLE OF CONTENTS

Introduction ................................................................................................ ......................................... Page 1

On Road Mobile Emission Summary ................................................................................................. Page 3

Latest Planning Assumptions ................................................................ .............................................. Page 5

Travel Demand Modeling - Analysis Years ....................................................................................... Page 5

Social-Economic Demographics ................................................................ ......................................... Page 5

Emission Factor Generation ................................ ................................................................................ Page 8

Temperature and Relative Humidity ................................................................................................ ... Page 9

Ramp Fraction ................................................................................................................................

... Page 10

Source Type Population .................................................................................................................... Page 11

Vehicle Age Distribution ................................

.................................................................................. Page 11

Road Type Distribution..................................................................................................................... Page 20

Post Processing ................................................................................................................................

. Page 21Transportation Air Quality Analysis And Technical Documentation Weirton-Steubenville

, WV

- OH State Implementation Plan MOVES Based Inventory for the U.S. EPA Eight-Hour Ozone Air Quality Standard

December 2012 Page ii 

### LIST OF TABLES

Table 1 BHJ Region On-Road Mobile Emissions by State ..................................................... Page 3

Table 2 BHJ Region On-Road Mobile Emissions by County ................................................. Page 4

Table 3 BHJ Region Representative Social-Economic Demographic Variables by

County 2005-2020 ................................................................................................ ...... Page 6

Table 4 Moves Inputs ................................

........................................................................... Page 8-9

Table 5 Average Temperature and Relative Humidity Data .................................................. Page 10

Table 6 Ramp Fractions ................................................................

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

Table 7 Source Type Population for Y ear 2005 ................................................................

.... Page 11

Table 8 Vehicle Age Distribution for Jefferson County, OH

.......................................... Page 12-15

Table 9 Vehicle Age Distribution for Brooke/Hancock County, WV ............................. Page 16-19

Table 10 Road Type Distribution for Brooke-Hancock-Jefferson

Non-Attainment Area................................................................................................ Page 20

LIST OF FIGURES

Figure 1 BHJ Geographic Area Fine Particulate Matter Non-Attainment Area Boundary

................................................................................................................................ ..... Page 2

Figure 2 BHJ Geographic Area Covered by Travel Demand Model and Traffic Analysis Zone Structure .................................................................................. Page 7Transportation Air Quality Analysis And Technical Documentation Weirton-Steubenville

, WV

- OH State Implementation Plan MOVES Based Inventory for the U.S. EPA Eight-Hour Ozone Air Quality Standard

December 2012 Page iii 

### SELECTED ABBREVIATIONS & ACRONYMS

BHJ

– Brooke-Hancock-Jefferson Metropolitan Planning Commission

CFR

– Code of Federal Regulations

FHWA

– Federal Highway Administration ;

FTA

– Federal Transit Administration ;

HC

– Hydrocarbons

HPMS

– Highway Performance Monitoring System

LRTP

– Long Range Transportation Plan

MOBILE6

– Mobile Source Emission Factor

Model

MOVES

– MOtor Vehicle Emission Simulator model required for regional emissions analyses for transportation conformity determinations

MOU

– Memorandum of Understanding

MPO

– Metropolitan Planning Organization

MVEB

– Motor Vehicle Emissions Budget

NAAQS

– National Ambient Air Quality

Standard

NOAA

– National Oceanic and Atmospheric

Administration

NO X 

### – Nitrogen Oxides

ODOT

– Ohio Department of Transportation

OEPA

– Ohio Environmental Protection Agency PM

– Particulate Matter

PM 2.5 

### - Particulate Matter with an aerodynamic diameter less than 2.5 microns (often referred to as Fine Particulate Matter)

PM 10



### – Particulate Matter with an aerodynamic

diameter less than 10 microns

SIP

– State Implementation Plan

STIP

– Statewide Transportation Improvement Program

TAZs

– Traffic Analysis Zones

TCM

– Transportation Control Measure

TDM

– Travel Demand Model

TIP

– Transportation Improvement Program in a Metropolitan Planning Area

USEPA

– United States Environmental Protection Agency

VHT

– Vehicle Hours of Travel

VMT

– Vehicle Miles of Travel

VOC

– Volatile Organic Compounds

WVDEP

– West Virginia Department of

Environmental Protection

WVDOT

– West Virginia Department of Transportation

### REVISION HISTORY

1. Submitted incorrect Table 2 on December 10, 2012 attachment

– 12/21/2012 (MJP)Transportation Air Quality Analysis And Technical Documentation Weirton-Steubenville

, WV

- OH State Implementation Plan MOVES Based Inventory for the U.S. EPA Eight-Hour Ozone Air Quality Standard

December 2012 Page 1



### Transportation Air Quality Analysis and Technical Documentation

For the Weirton-Steubenville, WV- OH State Implementation Plan Inventory Mobile Emission Estimates Using the USEPA Motor Vehicle Emissions Simulator Model

(MOVES 2010a) For the U.S. EPA Eight- Ho ur Ozone National Ambient Air Quality Standard

INTRODUCTION

This memorandum documents the air quality analyses and underlying planning assumptions performed for the U.S. EPA Eight-Hour National Ambient Air Quality Standard on-road mobile source emission inventories for the Weirton-Steubenville, WV-OH Metropolitan area State Implementation Plan (SIP). This analysis will update the emissions inventories using Mo tor Vehicle Emission Simulator (MOVES)

model based value estimat es . The Ohio Department of Transportation (ODOT), Division ofTransportation System Development-Modeling and Forecasting Section and the Brooke-HancockJefferson Planning Commission (BHJMPC) completed these analyses in coordination with the Ohio Environmental Protection Agency (OEPA) and West Virginia Department of Environmental Protection (WVDEP).

The BHJMPC serves as the Metropolitan Planning Organization (MPO). The MPO submitted the necessary 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 demand model based emission factors as well as the complete air quality analyses for the metropolitan area.

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. Both the State of Ohio and the State of West Virginia have submitted plans to USEPA that establish motor vehicle emission budgets (MVEB) for Nitrogen Oxides (NOx) and Volatile Organic Compounds (VOC), under the Eight-hour ozone standard. Each state has established separate budgets (i.e. NOx and VOC budgets for Jefferson County, OH and separate NOx and VOC budgets for the collective West Virginia Counties of Brooke & Hancock). On April 3, 2007, the USEPA circulated a Notice of Adequacy regarding the Jefferson County, Ohio budgets which became effective on April 18, 2007 (40 CFR Parts 52 and 81, Vol. 72 Federal Register 15879 -80 April 18, 2007). In the following month on May 16, 2007, the USEPA issued a determination of attainment, (40 CFR 52 and 81, Vol. 72 Federal Register 27640 -2 June 15, 2007) essentially re-designating Jefferson County as attaining the Eight-hour Ozone Standard in force June 15, 2007. Then, on July 5, 2007, the agency submitted a correcting amendment to the Jefferson County determination of attainment (40 CFR Part 52, Vol. 72 Federal Register 36599-60 Jul5, 2007). The revision modified language regarding the 2018 MVEB. On the other hand, USEPA issued an approval for a re-designation request

from non- at tainment to attainment for the Eight-hour Ozone Standard for Brooke and Hancock counties, West Virginia May 14, 2007 (40 CFR Part 52, Vol. 72 Federal Register 27060 -3 June 13, 2007). The

re -designation request became effective June 13, 2007 and included maintenance emission budgets for NOx and VOC. On September 15, 2011, the US EPA took final action to approve a SIP revision by the State of West Virginia (40 CFR 56975) to amend the Eight-hour Ozone Maintenance Plan for the Weirton, WV area. The revision amended the plan’s safety margins, increasing the area’s MVEB. This

action became effective November 14, 2011.Transportation Air Quality Analysis And Technical Documentation Weirton-Steubenville

, WV

- OH State Implementation Plan MOVES Based Inventory for the U.S. EPA Eight-Hour Ozone Air Quality Standard

December 2012 Page 2 

### Figure 1

BHJ GEOGRAPHIC AREA EIGHT-HOUR OZONE (1997 STANDARD)

MAINTENANCE AREA BOUNDARY

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# ., .Transportation Air Quality Analysis And Technical Documentation Weirton-Steubenville

, WV

- OH State Implementation Plan MOVES Based Inventory for the U.S. EPA Eight-Hour Ozone Air Quality Standard

December 2012 Page 3 

### ON ROAD MOBILE EMISSION SUMMARY

The Table 1 and 2 below present a summary of the pollutant emissions including Hydrocarbons (HC) and Nitrogen Oxides (NO

x 

### ) modeled for each county that make up the BHJ Region. The Model Years for the demonstration includes the Base Year 2002, Attainment Year 2004, and Budget Year Inventories

2009 and 2018.

Table 1

BHJ REGION ON-ROAD MOBILE EMISSIONS BY STATETransportation Air Quality Analysis And Technical Documentation Weirton-Steubenville

, WV

- OH State Implementation Plan MOVES Based Inventory for the U.S. EPA Eight-Hour Ozone Air Quality Standard

December 2012 Page 4 

### Table 2

BHJ REGION ON-ROAD MOBILE EMISSIONS BY COUNTYTransportation Air Quality Analysis And Technical Documentation Weirton-Steubenville

, WV

- OH State Implementation Plan MOVES Based Inventory for the U.S. EPA Eight-Hour Ozone Air Quality Standard

December 2012 Page 5 

### LATEST PLANNING ASSUMPTIONS

This report will present the latest population and land use data available that calibrated the modeling process used to calculate the vehicle emissions for the mobile emissions budgets as well as the input

values for U.S. EPA’s most recent emissions software MOVES2010a for this attainment demonstration.

TRAVEL DEMAND MODELING - ANALYSIS YEARS

A Travel Demand Model (TDM) is the traditional forecasting 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 assistance 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 route assignment performed with the Cube Voyager software package. The model Outputs generated 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 Year is 2000. The model uses comparable Average Daily Traffic count data, updated social-economic variables for 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 planned federal-aid projects as well as any regionally significant projects found in the BHJ TIP and LRTP expected to be open for traffic by the end of each respective analysis

year.

Interagency consultation established the following model years for this analysis:

Analysis Year 2002

–

Baseline Emissions Analysis Year 2004

–

Attainment Year Analysis Year 2009

–

Budget Year Inventory Analysis Year 2018

–

Budget Year Inventory

SOCIAL-ECONOMIC DEMOGRAPHICS

Identifying projected growth centers and understanding urban and rural population changes are essential to determine future transportation needs in a given study area. Critical elements include an

under standing 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 long-range tr ansportation improvements.

Travel forecasting procedures require the user delineate the TDM study area into geographic areas called Traffic Analysis Zones (TAZs). 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 attractors based on a set of demographic variables. The BHJMPO collects and reviews the TDM independent variables that characterize current and future

estimates o f the metropolitan area’s social and 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. Figure 2 displays the BHJTransportation Air Quality Analysis And Technical Documentation Weirton-Steubenville

, WV

- OH State Implementation Plan MOVES Based Inventory for the U.S. EPA Eight-Hour Ozone Air Quality Standard

December 2012 Page 6 

### MPO geography covered by the Steubenville-Weirton Travel Demand Model (the entire three-county area) including the Traffic Analysis Zone structure. The computer-based TDM for the SteubenvilleWeirton Metropolitan Area highway network employs the following land use variables:

[AREA_TYPE] ≡ Area Type [AVG_PARK] ≡ Average parking cost
[ENROLL] ≡ School en rollment classified by Private [ENROLL_PRIV], Public [ENROLL_PUB] and Post-secondary [ENROLL_UNIV] schools
[HOTEL_RM] ≡ Hotel Rooms
[MED_HHINC] ≡ Median household income
[POP] ≡ Population
[POP_18] ≡ Population 18 years or less
[POP_GRP] ≡ Population residing in Group Quarters
[TOTEMP] ≡ Total Employment grouped by the North American Industrial Classification System (NAICS)
[TOT_HH] ≡ Occupied housing
[TOT_VEH] ≡ Vehicles available per household
[WORKERS] ≡ Workers per household

Table 3 below is a set of demographic variables developed for this report.

Table 3

BHJ REGION

REPRESENTATIVE SOCIAL-ECONOMIC DEMOGRAPHIC

VARIABLES BY COUNTY 2005-2020Transportation Air Quality Analysis And Technical Documentation Weirton-Steubenville

, WV

- OH State Implementation Plan MOVES Based Inventory for the U.S. EPA Eight-Hour Ozone Air Quality Standard

December 2012 Page 7 

### Figure 2

BHJ GEOGRAPHIC AREA

COVERED BY TRAVEL DEMAND MODEL

AND TRAFFIC ANALYSIS ZONE STRUCTURE



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_____ , _______ _

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# • "Transportation Air Quality Analysis And Technical Documentation Weirton-Steubenville

, WV

- OH State Implementation Plan MOVES Based Inventory for the U.S. EPA Eight-Hour Ozone Air Quality Standard

December 2012 Page 8 

### EMISSION FACTOR GENERATION

The MOVES model generated the emission factor files were for base year-2005 and attainment year2008 representing the transportation improvement programs implemented in the BHJ Region. The model also generated emission factors for two future year scenarios 2015, 2022 , and 2025

.

Table 4 summarizes the settings used in the MOVES run specification file and the MOVES CountyData Manager. The subsequent tables provide the specific inputs that are not using the MOVES default

values.

Table 4

MOVES INPUTS

RunSpec Parameter Settings

MOVES Version MOVES2010A

Scale Custom Domain MOVES Modeling Technique Emission Factor Method Rates per Profile (grams/vehicle) Rates per Distance (grams/vehicle) Rates per Vehicle (grams/vehicle)
Time Span Time Aggregation: Hour 1 Month representing average summer temperatures All hours of day selected, 16 speed bins, weekdays only
Geographic Bounds Brooke, Hancock, and Jefferson counties
Vehicles/Equipment All source types, gasoline and diesel
Road Type All road types including off

- network

Pollutants and Processes Total Gaseous Hydrocarbons, Non

- Methane Hydrocarbons, Volatile
Organic Compounds, NO X 

### , NO, NO 2 

### , Total Energy Consumption

Strategies None
General Output Units = grams, joules and miles
Output Emissions Time = hour, Location = custom area, on

- road emission rates by road type and source use type

Advance Performance NoneTransportation Air Quality Analysis And Technical Documentation Weirton-Steubenville

, WV

- OH State Implementation Plan MOVES Based Inventory for the U.S. EPA Eight-Hour Ozone Air Quality Standard

December 2012 Page 9 

### Table 4 (continued)

MOVES INPUTS

County Data Manager Sources Source Type Population Combination of local and default data
Local data (2010) ODOT 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 d aily relative humidity for 2002

Ramp Fraction Using the Base Year Travel Demand Model for V HT fractions

Future fractions will be assumed constant
Road Type Distribution Use ODOT and WV Division of Highways county summary VMT categorized by federal functional classes
Age Distribution Combin ation 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

TEMPERATURE AND RELATIVE HUMIDITY

The single season approach for temperature and relative humidity uses weather data collected by the National Oceanic and Atmospheric Administration (NOAA) National Climatic Data Center (NCDC). The data used in this report, taken from the Pittsburgh International Airport collection center, is representative of 12 months in 2009. Data entered into a spreadsheet provided by U.S. EPA converted

the Mobile6 to get the correct data for the MOVES model . Listed in the table below are the average annual hourly temperatures and relative humidity distribution profiles for the Weirton-Steubenville,

WV -OH metropolitan area.Transportation Air Quality Analysis And Technical Documentation Weirton-Steubenville

, WV

- OH State Implementation Plan MOVES Based Inventory for the U.S. EPA Eight-Hour Ozone Air Quality Standard

December 2012 Page 10 

### Table 5

AVERAGE TEMPERATURE AND RELATIVE HUMIDITY DATA

RAMP FRACTION

The Base Year Travel Demand Model used the Vehicles Hour of Travel (VHT) fractions to derive the Ramp Fractions shown in Table 6

. The future year networks also used the base year fractions.

Table 6

RAMP FRACTIONSTransportation Air Quality Analysis And Technical Documentation Weirton-Steubenville

, WV

- OH State Implementation Plan MOVES Based Inventory for the U.S. EPA Eight-Hour Ozone Air Quality Standard

December 2012 Page 11 

### SOURCE TYPE POPULATION

A combination of local and MOVES default data is the Source Type Population for vehicle

classifications. The MOVES default values provided the data for Source Type Population 51, 52, 53, 61, and 62 while local data from Ohio and West Virginia motor vehicle registrations accounted for all other Source Type Population needed to run the MOVES model. Table 7 shows the Source Type Population identifications, the corresponding Source Type Name, and the number of vehicles analyzed for Jefferson County, OH and Brooke/Hancock County, WV combined.

Table 7

SOURCE TYPE POPULATION FOR YEAR 2005

VEHICLE AGE DISTRIBUTION

A grouping of data from Ohio and West Virginia sources along with the MOVES model defaults make up the Vehicle Age Distribution. MOVES default values included Vehicle Type ID 41, 42, 51, 52, 53, 61, and 62. Local data from Ohio and West Virginia motor vehicle registrations accounted for all other Vehicle Type ID. Table 8 and Table 9 show the Vehicle Age Distribution for Jefferson County, OH and Brooke/Hancock County, WV respectively.Transportation Air Quality Analysis And Technical Documentation Weirton-Steubenville

, WV

- OH State Implementation Plan MOVES Based Inventory for the U.S. EPA Eight-Hour Ozone Air Quality Standard

December 2012 Page 12 

### Table 8 VEHICLE AGE DISTRIBUTION FOR JEFFERSON COUNTY, OHTransportation Air Quality Analysis And Technical Documentation Weirton-Steubenville

, WV

- OH State Implementation Plan MOVES Based Inventory for the U.S. EPA Eight-Hour Ozone Air Quality Standard

December 2012 Page 13 

### Table 8 (continued) VEHICLE AGE DISTRIBUTION FOR JEFFERSON COUNTY, OHTransportation Air Quality Analysis And Technical Documentation Weirton-Steubenville

, WV

- OH State Implementation Plan MOVES Based Inventory for the U.S. EPA Eight-Hour Ozone Air Quality Standard

December 2012 Page 14 

### Table 8 (continued) VEHICLE AGE DISTRIBUTION FOR JEFFERSON COUNTY, OHTransportation Air Quality Analysis And Technical Documentation Weirton-Steubenville

, WV

- OH State Implementation Plan MOVES Based Inventory for the U.S. EPA Eight-Hour Ozone Air Quality Standard

December 2012 Page 15 

### Table 8 (continued) VEHICLE AGE DISTRIBUTION FOR JEFFERSON COUNTY, OHTransportation Air Quality Analysis And Technical Documentation Weirton-Steubenville

, WV

- OH State Implementation Plan MOVES Based Inventory for the U.S. EPA Eight-Hour Ozone Air Quality Standard

December 2012 Page 16 

### Table 9 VEHICLE AGE DISTRIBUTION FOR BROOKE/HANCOCK COUNTY, WVTransportation Air Quality Analysis And Technical Documentation Weirton-Steubenville

, WV

- OH State Implementation Plan MOVES Based Inventory for the U.S. EPA Eight-Hour Ozone Air Quality Standard

December 2012 Page 17 

### Table 9 (continued)

VEHICLE AG E DISTRIBUTION FOR BROOKE/HANCOCK COUNTY, WVTransportation Air Quality Analysis And Technical Documentation Weirton-Steubenville

, WV

- OH State Implementation Plan MOVES Based Inventory for the U.S. EPA Eight-Hour Ozone Air Quality Standard

December 2012 Page 18 

### Table 9 (continued) VEHICLE AGE DISTRIBUTION FOR BROOKE/HANCOCK COUNTY, WVTransportation Air Quality Analysis And Technical Documentation Weirton-Steubenville

, WV

- OH State Implementation Plan MOVES Based Inventory for the U.S. EPA Eight-Hour Ozone Air Quality Standard

December 2012 Page 19 

### Table 9 (continued) VEHICLE AGE DISTRIBUTION FOR BROOKE/HANCOCK COUNTY, WVTransportation Air Quality Analysis And Technical Documentation Weirton-Steubenville

, WV

- OH State Implementation Plan MOVES Based Inventory for the U.S. EPA Eight-Hour Ozone Air Quality Standard

December 2012 Page 20 

### ROAD TYPE DISTRIBUTION

The ODOT and WV Division of Highway county summary Vehicle Miles Traveled (V MT ) data categorized by federal functional class for the three county non-attainment areas is the basis for Road Type Distribution Fraction. Table 10 illustrates Road Type Distribution.

Table 10

ROAD TYPE DISTRIBUTION FOR BROOKE-HANCOCK-JEFFERSON

NON-ATTAINMENT AREATransportation Air Quality Analysis And Technical Documentation Weirton-Steubenville

, WV

- OH State Implementation Plan MOVES Based Inventory for the U.S. EPA Eight-Hour Ozone Air Quality Standard

December 2012 Page 21 

### POST PROCESSING

Several custom programs created by ODOT were computed the t otal emissions. The process uses data on daily and directional traffic distributions as well as more up to date volume/delay functions from the 2000 Highway Capacity Manual (HCM). This process, described below and illustrated in Figure 4, also uses rewritten code able to handle the newer model network formats and MOVES generated emission

factors.

The first step in the process involves running postcms.exe to calculate hourly link volumes based on the percentage of the daily volume (travel demand model output) determined by a link’s facility and area type. The analysis does not use the l ink speeds from the travel demand model. Using a link’s volume

to -capacity ratio and link group code, a post-process to the model based on HCM methods estimates the link speeds.

The second step (mmoves.exe) uses a combination of the MOVES emission factors and the hourly link volumes that are output of the postcms.exe program. The hourly volumes multiplied by the MOVES emission factor for the corresponding hour of day, speed bin, and road type ; calculate emissions for every network link for each hour. The final link on road vehicle emissions for the area is the sum of all

individual link-hour emissions.

The third step, (vehcalm.exe), calculates vehicle-based emissions for each source type for each hour of the day. A combination of local and default data is the source for the vehicle source type. The final vehicle emissions for each county are the sum of all individual hourly emissions for all vehicle types.

Since the intrazonal trips are not loaded onto the network, the fourth step in the process requires a separate method to account for those trips that use local roads to travel within a zone. The intracalm.exe program uses intrazonal trips to estimate VMT using the area in square miles and intrazonal trips of each zone. The computer program assumes that the zone is circular and uses the radius of the circle as the average trip length for these intrazonal trips. By combining MOVES generated emissions with estimated intrazonal VMT, the i ntrazonal emissions are then calculated. The emission rates are the same

as those used to calculated link based emissions.

The final step is to summarize link, vehicle, and intrazonal emissions for each county, pollutant, and analyzed year, and to multiply annual average daily emissions by 365 to produce an annual estimate.

### Public Notice Ohio Environmental Protection Agency Revision of Redesignation and Maintenance Plan for the Ohio portion of the

former Steubenville-Weirton WV-OH Ozone Nonattainment Area

Jefferson County, OH

Notice is hereby given that the Director of the Ohio Environmental Protection Agency, (Ohio EPA) is requesting that the United States Environment al Protection Agency (U.S. EPA) revise the current maintenance plan fo r the Ohio portion of the SteubenvilleWeirton WV-OH area (Jefferson County, OH ) with respect to the 1997 eight-hour ozone national ambient air quality standard (NAAQ S). Ohio EPA submitted a redesignation request and maintenance plan for this ar ea on July 31, 2006 Subsequently, U.S. EPA approved this requests on May 16, 2007 (72 FR 27640). Air quality monitoring data collected in the region demonstrated attainm ent of the NAAQS and there was evidence that the improved air quality is due to pe rmanent, enforceable emission reductions. In addition, existing requirements are suffici ent to maintain t he 1997 eight-hour ozone standard in this area throughout the maintenance period.

Ohio EPA is now requesting a revision to the maintenance plan to update mobile emission projections and conformity budget s based on emission rates generated from
U.S. EPA’s latest mobile emissions model , the Motor Vehicle Emission Simulation (MOVES) 2010. In December 2009, MOVES r eplaced MOBILE6.2 as the U.S. EPA’s

official emission factor model.

These actions must be noticed to allow public comment and to satisfy U.S. EPA requirements for public involvem ent in SIP related activities. This notice addresses Ohio EPA’s reliance on the emission projec tions as evidence of attainment and

maintenance and the commitment to institute contingency measures if ambient exceedances or violations trigger the cont ingency plan requirements. Written comments

will be received on or before March 4, 2013 at the following address:

E-mail: erica.fetty@epa.state.oh.us

Mailing address: Erica Fetty Ohio Environmental Protection Agency, DAPC
Lazarus Government Center
P.O. Box 1049 Columbus, Ohio 43216-1049 Phone: (614) 644-2310

Pursuant to Section 119.03 of the Ohio Revised Code, a public hearing on this redesignation request will be conducted as follows: March 4, 2013 at 1:15 P.M., Steubenville Schiappa Branch Library , 4141 Mall Drive, Steubenville, Ohio.

### All interested persons are entitled to att end or be represented at the hearings and give

written or oral comments on these changes. All oral comments presented at the hearing, and all written statements submitted at the hearing or to the above address by the close of business on March 4, 2013 will be considered by Ohio EPA prior to final action on this redesignation. Wr itten statements submitted after March 4, 2013 may be considered as time and circumstances permit, but will not be part of the official record of the hearing.

This redesignation and maintenance request is available on Ohio EPA DAPC’s Web page for electronic downloading at: http ://www.epa.ohio.gov/dapc/SIP/1997.aspx. Questions regarding accessing the web site should be directed to Arunee Niamlarb at 614-728-1342; other questions or comments about this document should be directed to either Erica Fetty, (614)-644-2310, Erica.Fetty@epa.state.oh.us or Jennifer Dines at (614) 644-3696, Jennifer.Dines@epa.state.oh.us or mailed to Erica Fetty or Jennifer

Dines at the above address.

### BEFORE THE OHIO EPA

- - -

IN RE: :

: Revision of Redesignation and :
Maintenance Plan for the Ohio Portion : of the Former Steubenville-Weirton : West Virginia-Ohio Ozone Nonattainment :

Area

- - -

Audiotaped public Hearing before

Moderator Kristopher Weiss, taken at the

Steubenville Schiappa Branch Library, 4141 Mall

Drive, Steubenville, Ohio, at 1:15 p.m. on March

4, 2013.

- - -

FRALEY, COOPER & ASSOCIATES 222 East Town Street, Second Floor Columbus, Ohio 43215-4620
(614) 228-0018 - (614) 852-6163
Fax - (614) 224-5724

- - -

### P-R-O-C-E-E-D-I-N-G-S

- - -

MODERATOR WEISS: My name is Kristopher

Weiss. I'm a public involvement coordinator in

Ohio EPA's Public Interest Center in Columbus. I

will be presiding over today's public hearing.

Thank you for taking the time to attend

this hearing before the Ohio Environmental

Protection Agency. The purpose of the hearing

today is to obtain comments from any interested

person regarding Ohio EPA's proposed action.

The State of Ohio is requesting that the

U.S. EPA revise the current maintenance plan for

the Steubenville/Weirton Ohio and West Virginia

area, which includes Jefferson County in Ohio,

with respect to the 1997 eight-hour ozone

national ambient air quality standard.

Ohio EPA is now requesting a revision to

the maintenance plan to update mobile emission

projections and conformity budgets based on

emission rates generated from U.S. EPA's latest

mobile emissions model, the Motor Vehicle

Emission Simulation 2010. In December 2009 MOVES

replaced MOBILE6.2 as U.S. EPA's official 2

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### emission factor model.

All interested persons are entitled to

attend or be represented and to present oral

and/or written comments concerning the proposed

action. All written and oral comments received

as part of the official record will be considered

by the Director of Ohio EPA.

To be included in the official record,

written comments must be received by Ohio EPA by

the close of business today, March 4, 2013.

These comments may be filed with me today or

e-mailed to erica.fetty@epa.ohio.gov.

All written comments submitted for the

record receive the same consideration as oral

testimony given today. Written statements

submitted after today may be considered as time

and circumstances permit but will not be part of

the official record for the hearing.

If you wish to present oral testimony at

this hearing today and have not already signed

the registration sheet, please do so at this

time. The sheet is available at the registration

table. People will be called in the order in

which they have registered. 3

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### There is no cross-examination of

speakers or of representatives of Ohio EPA in

public hearings such as this. Ohio EPA hearings

such as this afford citizens the opportunity to

provide comments on the official record.

Therefore, we will not be able to answer

questions during the hearing. However, members

of the panel may ask clarifying questions of the

person testifying to ensure the record is as

complete and accurate as possible.

I will now read the names of those who

have registered at this hearing and will give

each person an opportunity to testify.

Seeing that no one wants to testify, we

will now go off the record.

(Break taken.)

MODERATOR WEISS: We are now back on the

record.

Is there anyone else who wishes to

testify? (No audible response.)

Seeing no further requests for

testimony, I'll remind you that the written

comments can be submitted through 5 p.m. today.

Thank you for attending. 4

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### The time is now 1:45 p.m., and this

hearing is adjourned.

(Thereupon, the public hearing was

adjourned at 1:45 p.m. on Monday, March 4, 2013.)

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### C E R T I F I C A T E

- - -

STATE OF OHIO :

SS:

COUNTY OF FRANKLIN :

I, Jennifer L. Parish, Registered

Professional Reporter, do hereby certify that the

foregoing is a true, correct, and complete

transcription of the above-mentioned audiotaped

public hearing before the Ohio EPA to the best of

my ability.

DATED this 15th day of March, 2013.

_________________________ JENNIFER L. PARISH, RPR

NOTARY PUBLIC-STATE OF OHIO

My Commission Expires: November 23, 2014. 6

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### Di vision of Air Pollution Control

Response to Comments

Revised Redesignation Request and Maintenance Plan

For the 1997 8-Hour Ozone Standard for the Steubenville-Weirton Area

Agency Contact for this Package

Division Contact: (Erica Fetty, Division of Air Pollution Control, 614- 644 -2310, Erica.Fetty@epa.state.oh.us)

Ohio EPA held a public hearing in Columbus, OH on March 4, 2013, regarding the revised

Maintenance Plan for the former Steubenville-Weirton Ozone Nonattainment Area. This
document summarizes the comments and questions received at the public hearing and during
the associated comment period, which ended on March 4

, 2013 . Ohio EPA reviewed and
considered all comments received during the public comment period.

By law, Ohio EPA has authority to consider specific issues related to protection of the
environment and public health.

The name of the commenter follows the comment in parentheses.



### Comment 1 : This 2013 update is based upon a 2006 original document. The

narrative introduction should explain why the document is being updated (e.g., inter alia, to update the on-road (highway) emission estimates and Motor Vehicle Emission Budgets (MVEBs) using the most recent EPA approved software, MOVES). The narrative could benefit from general polishing and refreshing, including discussion of fundamental points raised below. ( William Durham- West Virginia Division of Air Quality )

Response 1 : Ohio EPA will be adding a footnote to the title page explaining the

purpose of the revision. Ohio EPA included updates to the narrative throughout this document to reflect the changes regarding the use of the new MOVES model. Where necessary, based on comments below, Ohio EPA has incorporated additional

clarification.

### Comment 2 : Any discussions related to the West Virg inia MVEB’s and Safety Margins should clearly reference the most recent EPA approved WV 1997 8-hour ozone budgets [see 76, Federal Register 56975, September 15, 2011; Weirton area summarized on page 56978; file attached in PDF]. Such discussions should clearly state that nothing in the Ohio proposal will change any of the EPA approved WV MVEB’s or Safety Margins. ( William Durham- West Virginia Division of Air Quality )

Response 2 : Ohio EPA has updated Table 7, the MVEBs, using those budgets

established for the WV portion of this area in the September 15, 2011 Federal Register. The footnote has also been clarified to describe the basis of West Virginia’s MVEBs. Subsequent tables and narrative have also been updated to reflect this change.

Comment 3 : For example, though the title of Table 7 refers to Jefferson County

(OH) MVEBs, the table also displays values for Brooke and Hancock (WV), which are incorrect and could mislead readers into thinking that the WV MVEBs have been, or are being, changed. This is absolutely NOT the case. ( William Durham- West Virginia Division of Air Quality )

Response 3 : Please see response to comment 2

Comment 4 : The same concern applies to Table 9, which displays WV on-road

emission estimates, then shows 15% increases as the resulting MVEBs (via asterisk-referenced text). Again, while the on-road emission estimates may be correct as now calculated using MOVES, the 2009 Interim and 2018 Maintenance values that have been flagged with asterisks are NOT the EPA approved MVEBs. The text should clearly state that the displayed values are shown ONLY for informational purposes and the EPA approved MVEBs should be shown in the document (this could be done in the narrative itself, in a separate table, or as a footnote). ( William

Durham- We st Virginia Division of Air Quality )

Response 4 : Please see response to comment 2

Comment 5 : Table 10 & Table 12 should then be revised to show the correct WV

values and resultant total safety margins.

The EPA approved values for WV total emissions [based upon augmented MOBILE6.2 on-road (highway) emission estimates,

### NOT MOVES; see 76 FR at 56978, Table 8 - portion labeled

Revised Total Emissions in the Revised Maintenance Plan (Tons/Day)] are:

2004 2009 2018

VOC: 13.5 13.4 13.4 tons per summer day

NOx: 18.2 18.0 17.9 tons per summer day ( William Durham- West Virginia Division of Air Quality )

Response 5 : Please see response to comment 2

Comment 6 : We suggest that a more comprehensive explanation of “safety

margin” would help clarify its meaning.

T he Transportation Conformity Rule (40 CFR 93.101) defines Safety margin as:

“[t]he amount by which the total projected emissions from all sources of a given pollutant are less than the total emissions that would satisfy the applicable requirement for reasonable further progress, attainment, or maintenance” (emphasis added).

To assure maintenance, the 2009 total emission estimates AND the 2018 total emission estimates, respectively, must be less than the 2004 maintenance plan base year total emissions (for a given pollutant/precursor). Thus, in the context of this maintenance plan, there are actually four safety margins:

2009 NOx; 2009 VOC; 2018 NOx; and 2018 VOC.

(Arguably, one could say there are a total of eight safety margins for the entire former nonattainment area, because the Ohio and West Virginia respective SIPs establish separate MVEBs for each state, with distinct resulting safety margins). These safety margins are calculated by subtracting the 2009 total emissions (for a given pollutant) and the 2018 total emissions (for a given pollutant), respectively, from the 2004 attainment year total emissions (for a given pollutant). We may refer to the results for a given pollutant/precursor as the 2009 safety margin and the 2018 safety margin , respectively. Portions of the original safety margins may be reallocated to the MVEBs as long as adequate margins remain to

ensure maintenance.

It is important to consider that transportation planning organizations typically develop a twenty year Long Range Transportation Plan

### (LRTP) while the initial air quality maintenance plan only lasts for ten years. Under the conformity rule, the last year of the LRTP must be tested against the MVEBs established for the last year of the maintenance plan. Therefore, future transportation conformity determinations will not only be made for the specific years contained in the maintenance plans but also for horizon years contained in the LRTP, which now may extend to the year 2040. That is, the future expected highway emissions, including growth, in 2040 will be compared against the 2018 MVEBs. Therefore, reallocation of appropriate portions of the safety margins into the respective MVEBs helps to assure future positive transportation conformity determinations while preserving good air quality. ( William Durham- West Virginia Division of Air Quality )

Response 6 : Ohio EPA has added additional clarification where necessary to

explain the origin of West Virginia’s safety margin. Beyond that, Ohio EPA is not updating additional language in this originally approved submittal. The purpose of this submittal is to revise the previously approved safety margin.

Comment 7 : We concur with Ohio EPA, that there are adequate remaining

safety margins to assure maintenance for the 1997 8-hour ozone standard. ( William Durham- West Virginia Division of Air Quality )

Response 7 : Thank you.