# Revision to the

Allegheny County Portion of the Pennsylvania State Implementation Plan

Attainment Demonstration for the Liberty

- Clairton

PM 2.5 

# Nonattainment Area

Allegheny County Health Department Air Quality Program

April 20 11Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page

- 2

- {This page lef

t blank for printing purposes}Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page i



# Table of Contents

List of Tables

................................ ................................ ................................ ................................ . i ii List of Figures

................................ ................................ ................................ ................................ i v List of Appendices

................................ ................................ ................................ ......................... v i Acronyms and Abbreviations

................................ ................................ ................................ ....... v ii

1. Executive Summary

................................ ................................ ................................ ................... 1 2. Regulation Changes

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

3. Problem Statement

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

3.1. Introduction

................................ ................................ ................................ ......................... 5 3.2. Monitoring

................................ ................................ ................................ .......................... 9 3.3. Data Analysis

................................ ................................ ................................ .................... 10 3.3.1. Regional, Urban, and Local Concentra tions

................................ .............................. 10 3.3.2. Speciation of PM 2.5 Data

................................ ................................ ............................ 12 4. Control Strategy

................................ ................................ ................................ ....................... 13 5. Explanation of Proposed Attainment Date

................................ ................................ .............. 17 6. Emissions Inventory

................................ ................................ ................................ ................. 18 7. Modeling Procedures

................................ ................................ ................................ ............... 21 7.1. Design

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

7.1.1. Protocol

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

7.1.2. Years Modeled

................................ ................................ ................................ ........... 23 7.2. Methodology

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

7.2.1. Sources Modeled

................................ ................................ ................................ ........ 24 7.2.2. Combination of Impacts

................................ ................................ ............................. 24 7.2.3. Reconstruction of Species

................................ ................................ .......................... 25 7.2.4. Modeled Source Groups

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

7 .2.5. Emissions Totals

................................ ................................ ................................ ........ 32 7.2.6. Combination of Impacts

................................ ................................ ............................. 32 7.2.7. Aggregation of Source Groups and Domains

................................ ............................ 33 7.2.8. Combination of Annual Impacts

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

7.2.9. Combination of 24

- Hour Impacts

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

8. Attainment Demonstration

................................ ................................ ................................ ....... 35 8.1. Monitored Data Assumptions

................................ ................................ ........................... 35 8.2. Annual Attainment Test Methodology

................................ ................................ ............. 3 5

8.3. 24

- Hour Attainment Test Methodology

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

8.4. Annual Standard Test Results

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

8.5. 24

- Hour Standard (65 μg/m3) Test Results

................................ ................................ ....... 41 8.6. Lincoln Area Analysis

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

8.7. Model Performance

................................ ................................ ................................ ........... 48 9. Reasonably Available Control Technology and Measures

................................ ...................... 58 10. Reasonable Further Progress

................................ ................................ ................................ .. 61 10.1. Reasonable Further Progress Requirements

................................ ................................ ... 61 10.2. Reasonable Further Progress Calculations

................................ ................................ ...... 62Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page ii

11. Co ntingency Measures

................................ ................................ ................................ ........... 65 11.1. Indentified Contingency Measures to be Implemented

................................ .................. 65 11.2. Contingency Measures

– SO 2 and NO

x ................................ ................................ .......... 66 11.3. Additional Contingency Measures

................................ ................................ .................. 67 12. Transportation Conformity

................................ ................................ ................................ .... 68 13. Weight of Evidence

................................ ................................ ................................ ................ 71 13.1. Local and Regional Trends

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

13.2. Wood Stoves & Wood

- Fired Boilers

................................ ................................ .............. 74 13.3. National Regulations

– CAIR and TR

................................ ................................ ............ 74 13.4. Diesel Campaign

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

13. 5. State and Competitive ARRA Clean Diesel Grants

................................ ........................ 77 13.6. Population Trends

................................ ................................ ................................ ........... 78 13.7. Monitored Data During Low Production

................................ ................................ ........ 80 14. Emergency Episodes

................................ ................................ ................................ .............. 85 15. Legal Documents

................................ ................................ ................................ ................... 86

15.1. Notic e of Public Hearing and Comment Period

................................ ............................. 86 15.2. Transmittals of Hearing Notice to PA DEP and EPA

................................ ..................... 87

15.3. Proof of Publication and Certification of Public Hearing

................................ ............... 90 15.4. Summary of Public Comments and Responses

................................ .............................. 92 15.5. Certifications of Approval and Adoption

................................ ................................ ..... 104

References

................................ ................................ ................................ ................................ ... 109Liberty

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LIST OF TABLES

Table 3

- 1 : Comparison of 2002 Liberty and Lawrenceville PM 2.5 Concentrations on Non

Inversion D ays

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

Table 6

- 1: Baseline 2002 Emissions ( T ons/ Y ear)

................................ ................................ ............. 20

Table 6

- 2: F uture Projected 2014 Emissions (Tons/Y ear)

................................ ................................ 20

Table 7

- 1: Modeled Emissions Totals

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

Table 8

- 1: Baseline Q uarterly Compositions

– Liberty Annual

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

Table 8

- 2: Modeled Relative Re sponse Factors (RRFs)

– Lib erty Annual

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

Table 8

- 3: Future Projected Quarterly Compositions

– Liberty Annual

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

Table 8

- 4: Liberty Annual Design Values

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

Table 8

- 5: Baseline Qu arterly Compositions

– Clairton Annual

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

Table 8

- 6: Modeled Relative Res ponse Factors (RRFs)

– Clairton Annual

................................ ...... 4 0

Table 8

- 7: Future Projected Qu arterly Compositions

– Clairton Annual

................................ .......... 4 0

Table 8

- 8: Clairton Annual Design Values

................................ ................................ ........................ 4 0

Table 8

- 9 : Baseline Quarterly High Days

– Liberty 24

- Hour

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

Table 8

- 10 : Baseline Quarterly Composit ions

– Liberty 24

- Hour

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

Tabl e 8

- 1 1 : Modeled Relative Re sponse Factors (RRFs)

– Liberty 24

- Hour

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

Table 8

- 1 2 : Future Projecte d Quarterly High Days

– Liberty 24

- Hour

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

Table 8

- 1 3 : Liberty 24

- Hour Design Values

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

Table 8

- 14: Baseline Quarterly High Days

– Clairton 24

- Hour

................................ ........................ 42

Table 8

- 15: Baseline Quarterly Compositions

– Liberty 24

- Hour (by p ercentage, applied to

Clairton high days)

................................ ................................ ................................ ......... 42

Table 8

- 16: Modeled Relative Response Factors (RRFs)

– Clairton 24

- Hour

................................ .. 42

Table 8

- 17: Future Projected Quarterly High Days

– Clairton 24

- Hour

................................ ........... 42

Table 8

- 18: Clairton 24

- Hour Design Values

................................ ................................ .................... 42

Table 8

- 19: Future Case Design Values

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

Table 8

- 2 0 : Statistics for the Modeled Daily Liberty Averages Compared to the Liberty FRM

V alues, Year

- Round and by Season , 2002

................................ ................................ ..... 53

Table 8

- 21 : Statistics for the Modeled Hour ly Liberty Values Compared to the Liberty TEOM

Values, Year

- Round and by Season , 2002

................................ ................................ ..... 5 7

Table 10

- 1: Emissions Inventory Adjusted for Plan Control Strategy (in Tons per Year)

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

Table 10

- 2: Determining Benchmark Milestones as Tons per Year of Reductions

.......................... 6 2

Table 10

- 3: Comparison of 2009 and 2012 RFP Benchmarks and Projected Levels

........................ 6 3

Table 10

- 4: Fraction of Reductions Achieved in Each Milestone Year

................................ ............ 6 3

Table 11

- 1: Calculation of Required and Excess Emission Reductions

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

Table 11

- 2: Contingency Measures Emi ssion Reductions

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

Table 12

- 1: Annual Motor Vehicle Emission Budgets (T ons/ Y ear)

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

Table 12

- 2: Daily Motor Vehicle Emission Budgets ( T ons/ Day )

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

Table 13

- 1: Future Case CAIR and TR Emissions

................................ ................................ ............ 75

Table 13

- 2: EGU Control Implementation Schedule and Progres s

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

Table 13

- 3 : PM 2.5 FRM Quarterly Averages , 2005

- 2008 and 2009

................................ .................. 83Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page iv

L IST OF FIGURES

Figure 3

- 1: Map of the Liberty

- Clairton Area within t he Pittsburgh

- Beaver Valley Area

............... 6 Figure 3

- 2: Daily PM 2.5 Concentrations D uring the 2002 Base Year, Comparing Mul tiple

Allegheny County Moni tors

................................ ................................ ........................... 7 Figure 3

- 3: 2002 B ase Y ear D ays with PM 2.5 C oncentrations H ighe r than 50 μg/m3 at the Liberty

M onitor and D ays w ith I nversions Greater than 3oC

................................ ..................... 8 Figure 3

- 4: PM 2.5 Annual Design Values S ince 2000

................................ ................................ ....... 1 0 Figure 3

- 5: Regional, U rban, and L ocal PM 2.5 C oncentrations

................................ ......................... 11 Figure 3

- 6: Localized Excess at Liberty

................................ ................................ ............................ 12 Fig ure 7

- 1: Modeling Domains

................................ ................................ ................................ .......... 22 Figure 7

- 2: Modeling Domains by Land Use and Terrain

................................ ................................ . 23 Figure 7

- 3: Combination of Mo deled Impacts for Total Carbons

................................ ..................... 25 Figure 7

- 4: Map of Mo deled Sources Outside Allegheny Co unty (no EGUs)

................................ .. 27 Figure 7

- 5: Map of Modeled EGUs

................................ ................................ ................................ ... 28 Figure 7

- 6: Map of Allegheny County So urce Groups and 20 km Domain

................................ ...... 29 Figure 7

- 7: Map of Modeled 20 km Domain Sources/Groups

................................ .......................... 30 Figure 7

- 8: Map of Near

- Field Sources wit h Building Parameters

................................ ................... 31 Figure 8

- 1: Receptor Grid for the Lincoln Area

................................ ................................ ................ 44 Figure 8

- 2: Annual Impacts by Percent Reduction in Lincoln Area

................................ ................. 45 Figure 8

- 3 : Annual Percent Reductions with Descriptions

................................ ................................ 4 6 Figure 8

- 4: 24

- Hour Impacts by Percent Reduction in Lin coln Area

................................ ................ 47 Figure 8

- 5 : Hourly Average Liberty Modeled and Monitored PM 2.5 (TEOM), Baseline 2002,

Year

- Round Basis

................................ ................................ ................................ ........... 48 Figure 8

- 6 : Hourly Average Liberty Modeled and Monitored PM 2.5 (TEOM), Baseline 2002,

Quarterly Basis

................................ ................................ ................................ ............... 49 Figure 8

- 7 : Hourly Average Liber ty Mode led Baseline and Future Cases, 2002 and 201 4

, Year

Round Basis

................................ ................................ ................................ .................... 50 Figure 8

- 8 : Hourly Average Liberty Modeled Base line and Future Cases, 2002 and 201 4

,

Quarterly Basis

................................ ................................ ................................ ............... 51 Figure 8

- 9 : Daily Average Liberty Modeled and M onitored (FRM), Baseline 2002

........................ 52 Figure 8

- 10 : Liberty Daily Mo del Statistics, Baseline 2002

................................ ............................. 54 Figure 8

- 11 : Liberty Modeled and Monitored Correlation, Daily Averages, Bas eline Case 2002,

Y ear

- Round Basis

................................ ................................ ................................ ......... 55 Figure 8

- 12 : Liberty Modeled and Monitored Correlation, Daily Averages, Baseli ne Case 2002,

Quarterly Basis

................................ ................................ ................................ .............. 56 Figure 12

- 1 : Confor mity Assessment for the Liberty

- Clairton Area, Annual PM 2.5

......................... 70 Figure 12

- 2: Confor mity Assessment for the Liberty

- Clairton Area, Daily PM 2.5

............................ 70 Figure 13

- 1: PM 2.5 FRM Annual Averages in Allegheny County, 200 0

- 200 9

................................ . 71 Figure 13

- 2: PM 2.5 FRM 3

- Year Average s in Allegheny County, 2000

- 2009

................................ .. 72 Figure 13

- 3: Liberty and Clairton Annual Design Values with Trend L ines

................................ .... 73 Figure 13

- 4: Population Trends for Allegheny County, 1990

- 2000

................................ .................. 79 Figure 13

- 5: Long

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

-

2008

................................ ................................ ................................ ............................... 80 Figure 13

- 6: Hourly 2009 PM 2.5 TEOM Averages at Liberty Compared to Long

- Term 2000

- 2008

Averages

................................ ................................ ................................ ....................... 81Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page v

Figure 13

- 7: Hourly 2009 PM 2.5 TEOM Averages at Lawrenceville Compared to Long

- Term

2000

- 2008 A verages

................................ ................................ ................................ ..... 82 Figure 13

- 8: Hourly 2009 PM 2.5 TEOM Average Differences B etween Liberty and

Lawrenceville Compared to Long

- Term 2000

- 2008 Data

................................ ............ 84Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page vi

LIST OF APPENDICES

Appendix A: Monitored Data and Inversion Analysis Appendix B : RACT Analysis by Source Appen dix C : Model Protocol for Liberty

- Clairton Modeling Appendix D : Meteorological Evaluation of Liberty

- Clairton Area Appendix E : ACHD PM 2.5 Speciation and PMF Analyses Appendix F : Liberty

- Clairton Emission s Inventories

F

- 1 : Stationary Point Sources

F

- 2 : Area Sources

F

- 3 : Nonroad Sources

F

- 4 : Mobile Sources Appendix G : MANE

- VU Inventory a nd Projection Documentation

G

- 1: TSD for 2002 MANE

- VU SIP Modeling

G

- 2: Development of Emission Projections

G

- 3: Emissions Processing for 2002 OTC

G

- 4: Future Yea r Emissions Inventory for OTC Appendix H : Modeling and R easonable Further Progress (RF P ) Inventories

H

- 1: Inventory Revisions

H

- 2: Inventory Listings Appendix I : Dispersion Model Files and Supporting Documentation

I

- 1: 20km Modeled Source Groups

I

- 2: 150km Modeled Source Groups

I

- 3: CALMET Settings

I

- 4: CALMET Differences from FLM

I

- 5: CALPUFF Settings

I

- 6: Battery Flow Rates and Plume Rise Treatment Appendix J : Attainment Demonstration

J

- 1: Annual Standard Attainment Test

J

- 2: 24

- Hour Standard Attainment Test

J

- 3: Impact Tables Appendix K : CMAQ Modeling Documentation

K

- 1: CMAQ Model Performance and Assessment

K

- 2: Meterological Modeling using MM5

K

- 3: Processing of 2002 Anthropogenic Emissions

K

- 4: PM 2.5 Modeling using SMOKE/CMAQLiberty

- Clairton PM 2.5 SIP Revision April 2011 Page vii

ACRONY MS AND ABBREVIATIONS

ACHD Allegheny County Health Department AQS Air Quality System (EPA)

BACT Best Available Control Technology

CAA Clean Air Act

CAIR Clean Air Interstate Rule

CALPUFF California Puff Dispersion Model

CALMET California Meterologica l Processor ( with CALPUFF)

CFR Code of Federal Regulations CMAQ Communit y Multis cale Air Quality Model

DON Degree of Neutralization

EC Elemental Carbon

EGU Electric Generating Unit

EPA The United States Environmental Protection Agency

FMVCP Federal Motor Vehicle Control Program

FLM Federal Land Managers

FR Federal Register

FRM Federal Reference Method M onitor

MANE

- VU Mid

- Atlantic/Northeast Visibility Union

MARAMA Mid

- Atlantic Regional Air Management Association

MATS Modeled Attainment Test Soft ware MM5 Mesoscale Model Version 5

MSA Metropolitan Statistical Area NAAQS National Ambient Air Quality Standard

NEI EPA National Emission Inventory Database

NLCD National Land Cover Data

NYSDEC New York State Department of Environmental Conservation

NO

x Oxides of Nitrogen

OC Organic Carbon

OCMmb Organic Carbon aceous Mass by Mass Balance

OTB/W On

- The

- Books/On

- The

- Way Regional Controls

PA DEP Pennsylvania Department of Environmental Protection

PBW Particle Bound Water

PIT Pittsburgh Internati onal Airport

PM Airborne Particulate Matter of any size

PM 2.5 Particulate Matter less than 2.5 microns in diameter, or Fine Particulates

PM 10 Particulate Matter less than 10 microns in diameter

RACM Reasonably Available Control Measure

RACT Reasonab ly Available Control Technology

RFP Reasonable Further Progress

RPO Regional Planning Organization

RRF Relative Response Factor

RVP Reid Vapor Pressure

SANDWICH Sulfate, Adjusted Nitrate, Derived Water, Inferred Carbonaceous Material

Balance ApproachLiberty

- Clairton PM 2.5 SIP Revision April 2011 Page viii

SIP State Implementation Plan

SMAT Speciated Modeled Attainment Test

SMOKE Sparse Matrix Operator Kernel Emissions System

SO 2 Sulfur Dioxide

STN Speciation Trends Network

TR Transport Rule

TEOM Ta pered Element Oscillating Microbalance M onitor

Ton s/year Tons per year of pollutant emissions

TSD Technical Support Document

USGS United States Geological Survey

μ g/m 3 Microgram per cubic meter

μm M icro meter

VMT Vehicle Miles Traveled

VOC Volatile Organic CompoundL iberty

- Clairton PM 2.5 SIP Revision April 2011 Page 1



## 1. Executive Summary

Particulate matter is a mixture of microscopic solids and liquid droplets suspended in air that

include: acid salts (such a s nitrates and sulfates), organic chemicals, metals, soil or dust particles

, and allergens (such as fragments of pollen or mold spores). Fine particle pollution or PM 2.5 describes particulate matter that is less than or equal to 2.5 micrometer (μm) in dia meter, approximately 1/ 3 0 th the diameter of a human hair.

Health studies have shown a significant association between exposure to fine particles and premature death from heart or lung disease. Fine particles can aggravate heart and lung diseases

and have been linked to effects such as cardiovascular symptoms, cardiac arrhythmias, heart attacks, respiratory symptoms, asthma attacks, and bronchitis. These effects can result in increased hospital admissions, emergency room visits, absences from school or wo rk, and restricted activity days. Individuals that may be particularly sensitive to fine particle exposure include people with heart or lung disease, older adults, and children.

The United States Environmental Protection Agency (EPA) published air quality designations

for the PM 2.5 standard based on air quality monitoring data from 2001

- 2003 in the Federal Register on January 5, 2005 (70 FR 944), effective on April 5, 2005. Included in the designations were the Pittsburgh

- Beaver Valley PM 2.5 nonattainment area and, within that area, a Liberty

- Clairton PM 2.5 nonattainment area. This SIP is an attainment demonstration of the Liberty

- Clairton area.

This SIP is a control strategy and attainment demonstration of the 1997 federal ambient

standards of 15 μ g/m 3 annual average and 65 μ g/m 3 24

- hour average PM 2.5

. More recently ne w standards were issued, of 15 μ g/m 3 annual average and 35 μ g/m 3 24

- hour average PM 2.5 . If necessary, a separate SIP submittal will be made to demonstrate attainment of these newer

standa rds at a later date. However, t he SIP included here adds the se new annual PM 2.5 standard

of 15 μ g/m 3 a nd the hourly standard of 35 μ g/m 3 t o the list of standards in ACHD Article XXI §2101.10 , since these are the standards at the present time.

The Pittsbu rgh

- Beaver Valley n onattainment area is located in southwestern Pennsylvania and consists of Beaver, Butler, Washington, and Westmoreland counties and portions of Allegheny, Armstrong, Greene and Lawrence counties. Located within the Pittsburgh

- Beaver Val ley Area is a separate nonattainment area entirely in southeastern Allegheny County. This is known as the Liberty

- Clairton nonattainment area, and comprises the boroughs of Glassport, Liberty, Lincoln, Port Vue, and the city of Clairton. The Liberty

- Clai rton PM 2.5 n onattainment a rea was designated as a separate, distinctively local

- source impacted, nonattainment area because the

combination of emissions from the local sources in a narrow river valley creates a local air quality problem uniquely different from the remainder of the Pittsburgh

- Beaver Valley a rea.

At the time of designation, the Liberty

- Clairton annual design value was 21.2 μ g/m 3 , based on

2001

- 2003 data; for 2006

- 2008 it is 18.3 μ g/m 3

. As this SIP demonstrates , attainment of the 15.0

μ g/m 3 standard i s expected to be reached by 2015 . The Pittsburgh

- Beaver Valley nonattainment area design value was 16.9 μ g/m 3 for 2001

- 2003; for 2006

- 2008 it is 15.2 μ g/m 3 . According toLiberty

- Clairton PM 2.5 SIP Revision April 2011 Page 2

the Pennsylvania Department of Protection PM 2.5 SIP, the Pittsburgh

- Beaver Valley area is projected to achieve a design value of 14.3 μ g/m 3 by 2010.

C ontrol measures that enable the Liberty

- Clairton area to d emonstrate attainment of the PM 2.5 NAAQS include:

The Clean Air Interstate Rule (CAIR) or its replacement and the NO

x “SIP Call” reducing interstate pollution transport; Upgrades and shutdowns to United States Steel Corporation (U. S. Steel) Clairton Plan t
batteries and quench towers

Other changes affecting the area not used in the modeled demonstrati on of attainment include:
Improve d performance to R R I Energy Elrama Plant emission control system Upgrades to U. S. Steel Edgar Thompson Plant Pennsylvania D iesel Idling Law Liberty

- Clairton voluntary municipal vehicle diesel retrofits Voluntary retrofit projects to several local diesel fleets including CSX Transportation, Port Authority of Allegheny County, Harsco Metals , and variou s construction vehicles

All egheny County voluntary school bus retrofit program Voluntary woodstove changeout program

Through these measures, Liberty

- Clairton is anticipated to be in attainment by 201 5 , due to the heavy reliance on U. S. Steel Clairton Plant upgrades which will be c ompleted by 201 4

.

The emission inventories used for this SIP was based on the regional MANE

- VU (Mid

Atlantic/Northeast Visibility Union) inventories developed for long

- range ozone, PM 2.5 , and haze planning. ACHD corrected the total primary PM 2.5 (filter able + condensable) inventory for key sources in order to accurately address local emissions and incorporate reductions not previously included in regional modeling. This corrected inventory was then used to represent carbons in Liberty

- Clairton, which ha ve been shown to be the majority of excess primary PM 2.5 . Regional inventories for other precursors or components of PM 2.5 were not modified for this SIP.

Years included in the inventory and modeling were 2002 for baseline case and 2014 for future projec ted case. For future case, uncorrected source emissions are as given in the 2012 MANE

VU inventory, while ACHD corrections were made according to a 2014 timeline. The future case inventory may be considered a conservative hybrid of 2012 and 201 4 since it does not account for possible additional reductions in the 2012

- 201 4 timeframe.

The modeling demonstration utilized a combination o f the regional Community Multis cale Air Quality (CMAQ) modeling using the MANE

- VU inventory and local CALPUFF modeling usin g the local corrected ACHD inventory. Procedures for modeling and attainment tests were followed according to EPA Modeling Guidance of April 2007 and the Allegheny County Health Department (ACHD) Liberty

- Clairton PM 2.5 modeling protocol, dated October 15, 2007. Changes from the protocol are documented in this SIP. Work on the modeling was shared with an advisory modeling workgroup. Modeled impacts from regional and local modeling were

combined on a conservation

- of

- mass basis, avoiding double

- counting fr om different model runs.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 3

Attainment test methodology was used to combine final modeled results with actual monitored

results over the 2000

- 2004 timeframe. Total mass was reconstructed by PM 2.5 species by the SANDWICH technique ( s ulfate, a djusted n itrate, d erived w ater, i nferred c arbonaceous material balance approac h ).

Results from the attainment demonstration showed an overall reduction of sulfates, nitrates, and primary PM 2.5 emissions throughout the Southwest PA domain, including 878 tons of primary

pa rticulate from the nonattainment area, leading to the following future projected design values for Liberty and Clairton:

Projected Annual Design Values (Standard = 15.0 μg/m3) Liberty 14.3 μg/m3

Clairton 11. 8 μg/m3

Projected 24

- Hour Design Values (Stand ard = 65 μg/m3) Liberty 42 μg/m3

Clairton 27 μg/m3

A Reasonably Available Control Technology (RACT) and Reasonably Available Control Measures analysis was made for the nonattainment area. No additional controls, or combination of additional controls, w ould advance the attainment date by one year, so RACT and RACM are

satisfied for this SIP.

A demonstration of Reasonable Further Progress is provided in this SIP. The most significant emission changes for primary PM 2.5 will be the installation of new co ke batteries and quench

towers at the U. S. Steel Clairton Plant

, along with the closure of older units at that facility

.

This SIP contains a contingency plan that provides assurance that should the Liberty

- Clairton

area fail to meet a milestone, or fail s to attain the NAAQS by the attainment date, the area can be brought back into attainment as expeditiously as practicable.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 4



## 2. Regulation Changes

The following regulation change s w ere made to Allegheny County’s Article XXI in accordance

with this SIP Re vision. The se regulation change s w ere enacted by County Ordinance 11

- 10

- OR and became effective on May 24, 2010.

§2101.10 AMBIENT AIR QUALITY STANDARDS

The following ambient air quality standards are hereby adopted as part of this Article. The

valu es specified herein represent minimum acceptable air quality, not necessarily desirable or satisfactory air quality. The adoption of these ambient air quality standards shall not in any manner relieve any person from the duty to fully comply with all requ irements of this Article in

areas where the concentration of air contaminants is less than such standards.

CONTAMINANT CONCENTRATIONS AVERAGED OVER 1 yr. 3 mos. 30 days 24 hrs. 8 hrs. 3 hrs

PM

- 10

National Pr imary & Secondary 50 a 150 a County 450 d
County Free Silica Portion 100 d



### PM

- 2.5 National Primary & Secondary 15 i 

### 35 i

. . .

i as determined pursuant to 40 CFR 50.7 and Appendix N ther eto

. . .

§2101.20 DEFINITIONS

. . .



### "PM

- 2.5 " means particulate matter with an aerodynamic diameter less than or equal to a nominal two and one

- half (2.5) micrometers as measured by an applicable reference method, or equivalent or alternativ e method, specified by EPA or by method specified in this Article.

. . . Additions are in large print, bold, and underlined.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 5



## 3. Problem Statement

3.1

. Introduction

The Clean Air Act requires a State Implementation Plan (SIP) to be written for any area designated nonattainment for the annual PM 2. 5 pollution standard of 15 .0 μg/m3. I n 2005

, the United States Environmental Protection Agency (EPA) determined that the Liberty

- Clairton

a rea, a 12 square kilometer subset of both Allegheny County and totally within the borders of the Pittsburgh

- Beaver V alley PM 2.5 nonattainment area, to be a separate PM 2.5 nonattainment area. The area was de signated separate from the surrounding Pittsburgh

- Beaver Valley a rea because of how pollutant concentrations are affected by specific features of Liberty

- Clairton.

The Liberty

- Clairton n on a ttainment a rea, consisting of Glassport, Liberty, Lincoln , and Port Vue

B oroughs and the C ity of Clairton , is located roughly 10 miles sout heast of the city of Pittsburgh

. The area is made up of complex river valley terrain, appr oximately 3 miles wide by 5 miles long.

It includes a 4

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

- Clairton area is about 25,000 people, about 1% the po pulation of the Pittsburgh M etropolitan Statistical Area (MSA).

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

- 7° F) during clear, low

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

- 4 mph

downward flows.

The Liberty

- Clairton a rea is home to several industrial sources of PM 2.5 pollution. U. S. Steel

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

- Clairton a rea is also home to Koppers Industries, Inc .’s

Clairton Tar Plant

, seven permitted minor sources, as well as numerous minor sources that do not require operational permits. Mid

- Continent Coal and Coke was previously classified as a ma jor source during 200 0

- 2002.

The Pittsburgh

- Beaver Valley PM 2.5 non attainment area consists of Allegh eny ( without the Liberty

- Clairton area ), Beaver, Butler, Washington, and Westmoreland Counties , the municipalities of Washi n gton, Elderton, and Plumcreek in Armstrong County, Mon on gahela Township in Greene County, and Taylor Township in Lawrence County

.

The Liberty

- Clairton PM 2.5 nonattainment area was designated a separate nonattainment area from the surrounding Pittsburgh

- Beaver Valley nonattainment area because, in addition to the regional air quality problem, there is a localized air quality issue in the local sources and the specific geologic and meteorological features of the area. Large industry locate d along the river sides in the valley. The shar p difference in elevation between the industrial and residential areas

and the high hillsides surrounding them create a significant river basin, and spikes in localized

PM 2.5 concentrations coincide with temperature inversions.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 6

The Liberty

- Clairton and Pi ttsburgh

- Beaver Valley PM 2.5 nonattainment areas are shown in Figure 3

- 1 below

.

Figure 3

- 1: Map of the Liberty

- Clairton Area within the Pittsburgh

- Beaver Valley AreaLiberty

- Clairton PM 2.5 SIP Revision April 2011 Page 7

Figure 3

- 2 shows average daily PM 2.5 concentration at multiple Allegheny County sit es. Moon, South Fayette, North Park, South Park, and Springdale monitors were omitted d ue to their low sampling rate.

O n many days the PM 2.5 concentration measured at the Liberty monitor reads very similar to all

the other monitors in the re g ion. Howeve r, when the regional concentrations rise, Liberty

concentrations clearly r ise higher than any other site. This happens frequently enough, and extremely high enough (up to 50

- 60 μ g/m 3 above the other monitors on a 24

- hour basis), that a control strategy needed to be considered for this area separate from , but in addition to, the control strategy f

or the rest of the Pittsburgh

- Beaver Valley non attainment area.

Figure 3

- 2: Dail y PM 2.5 C oncentrations D uring the 2002 B ase Y ear, C omparing M ultiple Allegheny County M onitors

A temperature inversion occur s when the air at the bottom of the basin becomes cooler than the air above it, i.e., the rate of cooling of the air is greatest a t ground level whereas the rate of cooling of the air is less at elevated levels

. The cooler air then becomes trapped at the lower elevation, filling the basin. As the major and minor sources of the area continue to emit PM 2.5 pollution, the lower, coole r air becomes buoyantly stable and unable to move upward to disperse into the regional flow. Figure 3 .3 shows a comparison between base

- year days in which PM 2.5Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 8

concentrations were above 50 μg/m3 at Liberty and days when temperature inversions greater

tha n 3o Celsius occur.

Figure 3

- 3: 2002 B ase Y ear D ays with PM 2.5 C oncentrations H igher than 50 μg/m3 at the

Liberty Monitor and D ays with I nversions G reater than 3oC

Three days in June and July had PM 2.5 concentrations greater than 50 μg/m3 without the presence of an inversion. However, as seen in Table 1, on the inversion

- free high days the Liberty monitor was on average 10.2 μg/m3 higher than the urban Lawrenceville monitor, which is

loc ated in the city of Pittsburgh.

Additional inversion analysis i s given in Appendix A. This analysis includes hourly continuous monitor averages with and without Liberty data during inversion days.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 9

Table 3

- 1 : Comparison of 2002 Liberty and Lawrenceville PM 2.5 C oncentrations on N on

I nversion D ays

Date Liberty

(μg/m3) Lawrenceville

(μg/m3) Difference

(μg/m3)

6/11/2002 54.9 41.4 13.5

6/25/2002 62.6 51.7 10.9

7/18/2002 54.5 48.4 6.1

As per normal valley inversion action, the local PM 2.5 is released into the upper atmospheric flow upon th e inversion’s break. After the inversion break, the Liberty monitor returns to a level comparable to, and often less than, the concentrations measured at surrounding monitors.



### 3 .2

. Monitoring

PM 2.5 monitoring currently takes place at 8 different monit oring locations throughout Allegheny County. The Lawrenceville monitor, located roughly 2 miles from downtown Pittsburgh, is generally used to define urban concentrations of PM 2.5 , and can be used to judge regional

concentrations. Two Federal Reference M ethod (FRM) PM 2.5 monitors are used in the Liberty

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

- Clairton area. The FRM monitor at Clairton is located atop a school at low elevation

in the western portion of the area. Both were violating the annual PM 2.5 standard of 15 μg/m3 during the design year of 2002. FRM monitor s located to the west and to the south of the area (South Park and Forward) have monitored attainme nt of both standards. A ppendices A (monitored data) and C (model protocol) contain more details of monitor sites and data.

Liberty and Clairton annual design values are given below in Figure 3

- 4. The Clairton monitor

is located in the general upwind direction of the Liberty mo nitor, causing readings to be nearly 4 μg/m3 lower at Clairton than at Liberty for the 200 7

- 200 9 Design Value. Clairton concentrations

s h ow a distinct decline since the ’ 00

- ’0 2 average, whereas movement at the Liberty monitor is

smaller. Though located w ithin the Liberty

- Clairton n onattainment a rea, the Clairton monitor reflects the decline consistent with the entire Pittsburgh

- Beaver Valley a rea, whereas the Liberty monitor remains constant due to the local sources and the meteorological conditions of th e area.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 10 Figure 3

- 4 : PM 2.5 Annual Design Values S ince 2000



### 3. 3

. Data Analysis

The average 5 μg/m3 difference between annual PM 2.5 concentrations in Liberty and other monitors within the Pittsburgh

- Beaver Valley n onattainment a rea can be attributed to the spikes in daily averages at Liberty. Primarily cau sed by inversions, as shown in S ection 3.1 , the days which can range as high as being 30 μg/m3 above Lawrenceville monitor data cause the annual average increase. Days which are not affected by inv ersions show Liberty following surrounding daily averages. Analyzing PM 2.5 concentrations and inversion days shows a strong correlation

between the two.

3. 3.1

. Re gional, Urban, and Local C oncentrations

The localized excess in the Liberty

- Clairton area has been determined through speciation data analysis

. Up to 75% of ambient PM 2.5 concentrations in the Pittsburgh

- Beaver Valley Metropolitan Statistical Area (MSA) can be attributable to upwind sources in Ohio, West Virginia, Indiana, and Michigan. This becomes roughly 11

- 13 micrograms per cubic meter of all

the PM 2.5 pollution in the Pittsburgh

- Beaver Valley nonattainment area. The same is true about the Liberty

- Clairton nonattainment area, as it is a part of the Pittsburgh

- Beaver Valley MSA. On

non

- in version days, pollutant levels in the Liberty

- Clairton area match those of the greaterLiberty

- Clairton PM 2.5 SIP Revision April 2011 Page 11

region. However, the inversion

- caused spikes average out to add roughly 5 μg/m3 to the annual average, causing the nonattainment (source apportionment results based on speciated data can be found in the report Allegheny County PM 2.5 Source Apportionment Results using the Positive Matrix Factorization Model (PMF Version 1.1). 1 )

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

Cl airton a rea to the surrounding areas. The Lawrenceville monitor, located in the city of Pittsburgh, serves as a baseline for the regional averages of PM 2.5

. The average 16.1 μg/m3

PM 2.5 concentration at the Lawrenceville monitor, impacted both by urban e xcess and the average 11

- 13 μg/m3 from out

- of

- state sources, increases to 20.7 μg/m3 at the Liberty monitor, signaling a localized excess of emissions at Liberty of 4.4 μg/m3. Figure 3

- 5 shows the speciation of both monitors, including the localized exces s at Liberty.

Figure 3

- 5 : Regional, U rban, and L ocal PM 2.5 C oncentrations

The following F igure 3

- 6 shows a close

- up of the localized excess at Liberty by species (i.e., the subtracted species shown in Figure 3

- 5). The “ other” component represents the difference between total mass and the sum of the major species. “Other” component can include particle bound water, trace elements, or compounds not measured.

1 Report can be found online at http://www.achd.net/airqual/pubs/pdf/pmf0106.pdf and in Appendix E

.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 12 Figure 3

- 6 : Local ized Excess at Liberty



### 3. 3.2

. Speciatio n of PM 2.5 

### D ata

Results from the Liberty PM 2.5 speciation monitor show that carbons, ammoni um , and some

trace elements are higher in the Liberty

- Clairton a rea than in other monitored areas by 4 to 5 μg/m3. An in

- depth analysis of speciated PM 2.5 componen ts in Allegheny County can be found in the report PM

2.5 Chemical Speciation and Related Comparisons at Lawrenceville and Liberty:

18

- Month Results. 2

2 Report can be found online at http://www.achd.net/airqual/pubs/pdf/speciation_report.pdf a nd in Appendix E

.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 13



## 4. Control Strategy

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

- Clairton nonattainment area.

Clean Air Interstate Rule (CAIR )

– EPA’s CAIR (70 FR 25162, May 12, 2005) was remanded to EPA for revisions by the United States Court of Appeals for the District of Columbia on December 23, 2008. EPA h as proposed the Transport Rule (TR) a s a replacement rule to CAIR,

to be effective in 2011. The Transport Rule is expected to b e as strict as or strict er than the 2005

CAIR. A comparison of CAIR and proposed TR emissions and controls can be found in the weight of evidence section of this document.

Pennsylvania transitioned from the NO

x SIP Call to the federal CAIR in 2009. CAIR is to provide the incentive for large electric generation units (EGUs) to reduce emissions below 2002 levels throughout the 28

- state CAIR region. Pennsylvania and other nearby states were required to adopt a regulation implementing the requirements of the CAIR or an equivalent program. EPA approved the Pennsylvania CAIR program on December 10, 2009. On April 28, 2006, the EPA p romulgated Federal Implementation Plans (FIPs) to reduce the interstate transport of NO

x and SO 2 that contribute significantly to nonattainment and interfere with maintenance of the 8

- hour ozone and PM 2.5 NAAQS. The EGUs in Pennsylvania will be regulated under the FIP until the EPA approves a SIP revision for the implementation of CAIR for the affected EGUs, at which point the approved CAIR SIP revision will supersede the FIP requirements in Pennsylvania. The Pennsylvania CAIR regulation was published in the Pennsylvania Bulletin on April 12, 2008. (38 Pa.B. 1705). The Department submitted the SIP revision to the EPA on May
23, 2008.

Interstate Pollution Transport Reduction

– In response to the federal NO

x SIP call rule, Pennsylvania and other covered states adopted NO

x control regulations for large industrial boilers and internal combustion engines, EGUs, and cement plants. The regulation covering industrial boilers and electric generators required emission reductions to commence May 1,
2003, while th e regulation covering large internal combustion engines and cement plants required emission reductions to commence May 1, 2005. The EPA approved these regulations, found in 25 Pa. Code Chapter 145, on August 21, 2001 (66 FR 43795) and September 29, 2006 ( 71 FR 57428).

U

. S

. Steel Mon Valley Works

– A consent order and agreement between ACHD and United States Steel Corporation (U. S. Steel) was signed in March 2008 , and amended in September

2010

, requiring a number of actions at the U. S. Steel Mon Valley Works Clairton and Edgar

Thomson Plant s in response to a number of visible emissions and opacity violations. These

actions at the U

. S . Steel Clairton Plant include a number of installations and shutdowns, rebuilding of coke ovens, and other miscellaneou s actions. Th e consent order and agreement is incorporated in the installation permit for the proposed Quench Towers 5A and 7A , constituting

a fe dera lly

- enforceable agreement. The actions used in the attainment demonstration are as

follows:Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 14

U. S. Steel Clairton Plant:

Batteries 7, 8, and 9

– Batteries 7

- 9 were permanently shut down on April 16, 2009 . The origi nal date for shut down was December 31, 2012 in the consent order and agreement

. It is expected that the proposed new C B attery will replace the production of B atteries 7

- 9 at significantly lower emissions.

Battery 19

– U. S. Steel will replace 25 heating walls on Battery 19 by October 31, 2012. The battery will meet its opacity limits by December 31, 2012, including, as necessary, implementing an advanced patching plan.

Quench Towers 5 A and 7 A

– In September 2010, ACHD and U. S. Steel amended the March 2008 consent order and agreement t o include the construction of new low emission quench towers for Batteries 13

- 15 and Batteries 19

- 20 by Decemb er 31, 2013. The new Quench Towers 5A and 7A will be used as the primary quench towers for Batteries 13

- 15

and Batteries 19

- 20, respectively. The current Qu ench Towers 5 and 7 will serve as auxiliary quench towers.

Other actions by U. S. Steel included in the attainment demonstration are as follows:

U. S. Steel Clairton Plant :

B Battery

– In June 2007, ACHD and U. S. Steel entered into a consent order and agreement

to rebuild the B Battery heating walls, completed by June 30, 2010.

Other actions not included in the attainment demonstration but included in the U. S. Steel

March 2008 consent order and agreement (amended in September 2010) are as follows :

U. S. Steel Clairton Plant :

Battery 15

– U

. S. Steel completed three rounds of an enhanced preven tive maintenance refractory repair plan, and the battery achieved compliance with its opacit y limits by December 31, 2008.

Battery 20

– U. S. Steel will replace 88 heating walls by October 31, 2014, and the battery will meet its opacity limits by December 31, 2014 including, as necessary, an advanced patching plan and a revitalization plan of the battery heating system.

U. S. Steel Edgar Thomson Plant :

B asic Oxygen Process (B OP )

– U. S. Steel implement ed an e nhanced o perating and

m aintenance p lan for the mixer baghouse and gas cleaning system

, received an installation permit, and complete d construction of an upgrade to the BOP emission capture system

, andLiberty

- Clairton PM 2.5 SIP Revision April 2011 Page 15

achieve d compliance with the visible emission standards at the BOP r oof monitor by June 30,

2009

.

La dle metallurgical furnace ( LMF )

– U. S. Steel has implemented an e nhanced o perating

and ma intenance p lan for the LMF

, received an installation permit for an upgrade to the LMF baghouse , and will complete the insta llation by August 31, 2010.

Other measure s not included attainment plan are as follows :

R R I Energy Elrama Plant

– In 2007, Orion Power Midwest (now RRI Energy) and the PA

DEP entered into a c onsent o rder and a greement to address exhaust stack opacity. The consent order and agreement requires Or ion Power Midwest to continue efforts to improve scrubber performance and to enhance boiler and ESP performance. This consent order and agreement did not require PADEP plan approvals, and the impact is difficult to calculate, so the emission change was no t included, however this should improve air quality in the nonattainment area.

Wood Stove Changeout Campaign

– In 2005 through 2007, ACHD participated in EPA’s Wood Stove Changeout Campaign, replacing 17 6 older woodstoves in the Southwest ern Pennsylvania area with newer, cleaner units, resulting in an approximate 9 tons per year of total particulate removed.

Harsco Metal

– Harsco Metals North America provide s trucking for U. S. Steel. With American Recovery and Reinvestment (ARRA) funds

, Harsco will volu ntarily install diesel particulate filters on 11 dump trucks operating in and around U. S. Steel's Mon Valley Works. Once upgraded, these dump trucks will be 90

- percent less polluting than they are today. It is estimated that these diesel particulate filt ers will remove 0. 06 tons of particulate matter per year,

0. 20 tons of carbon monoxide per year, and 0.91 tons of hydrocarbons per year.

V oluntary D iesel R etrofits

– An ACHD fund has been allocated to provide voluntary diesel retrofits to municipal vehicl es in t he municipalities within the Liberty

- Clairton nonattainment area. It is unknown at this time how many vehicles will be retrofit ted , and the amount of particulates that will be reduced.

CSX Transportation

– With ARRA funds, CSX Transportation will replace one vintage diesel

switcher locomotive without emission controls with a two

- engine GenSet switcher locomotive engine

, cut ting diesel particulate matter by approximately 0.5 tons per year, carbon dioxide by 172 tons per year, and nitrogen oxides by 16.6 tons per year. It will also save 15,000 gallons of diesel fuel annually and provide quieter operation for the nearby residents of McKeesport.

The Port Authority of Allegheny County

– The Port Authority of Allegheny County will use ARRA funds for repl acing two 1996

- model transit buses with 2010

- model cleaner diesel hybrid electric buses and to repower nine 2003

- model diesel buses with engines that meet the new, higher 2007 emission standards. This will reduce particulate matter pollution by approximate ly 0.1 tons per year, carbon monoxide by 2.8 tons per year, and nitrogen oxides by 6.8 tons per

year.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 16

Constructors Association of Western Pennsylvania

– Constructors Association of Western Pennsylvania will use ARRA funds for retrofit technologies

– engin e repowers, upgrades

, and diesel particulate filters

– to upgrade 23 diesel

- powered, heavy non

- road construction equipment in Western Pennsylvania. The various upgrades will reduce particulate matter pollution by 1.8 tons per year, carbon monoxide by 14.6 tons per year, hydrocarbons by 2.09 tons per year, and nitrogen oxides by 9.73 tons per year.

The City of Pittsburgh

– The City of Pittsburgh will retrofit approximately 33 diesel engine municipal waste haulers with emission

- reducing technology

.

Diesel Idling Regulations

– Both Allegheny County and Pennsylvania recently adopted a state

wide ban on unnecessary diesel idling . Drivers of diesel engine vehicles can be reported to ACHD and can be fined up to $500 if they are found to idle unnecessarily for mo re than 5

minutes in a one

- hour period. Outreach and public education for these new regulations are currently underway.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 17



## 5. Explanation of Proposed Attainment Date

Section 172(a)(2) of the CAA states that an area’s attainment date “shall be the date by which attainment can be achieved as expeditiously as practicable, but no later than 5 years from the date such area was designated nonattainment.” Liberty

- Clairton was designated as

nonattainment for annual PM 2.5 as of 2005. Therefore the initial 5

- year attainment date for PM 2.5 would be 2010.

An agency may request an extension of that attainment date for up to 5 years, with reason for the need of this extension. This SIP proposes an attainment date of 2015. The extended attainment

date is necessar y in this case in order for U. S. Steel to complete construction of new equipment

as pe r consent order and agreement.

The consent order and agreement between ACHD and U

. S

. Steel made in March 2008 outlined plans to shut down Batteries 7, 8, and 9 and rep lace them with a new Battery C

, based on a newer and cleaner design. This project reduces emissions of direct PM 2.5 by approximately 208 tons per year, at a cost of about $500 million.

As part of an amendment to the consent order and agreement ( in Septem ber 2010 ) , U . S. Steel additionally agreed to construct new low emission quench towers for Batteries 13

- 15 and

Batteries 19

- 20. The new Q uench T owers 5A and 7A will reduce emissions of direct PM 2.5 by 593 tons per year. The quench tower installations are scheduled for completion by December 31,

2013.

These upgrades represent an extensive and expensive modernization of this facility. No combination of additional source changes or upgrades in the nonattainment area can provide the tonnage of emissions dec reases or bring the date forward by a year. Therefore, the attainment

date must be extended from 2010 to 2015.

M odeling in this SIP includes regional modeling done by MANE

- VU, which contains CAIR, a program now remanded to EPA. EPA has proposed the Tran sport Rule (TR) a s a replacement rule to CAIR, to be effective in 2011. This should not change the attainment date, either to move it forward or to delay it further. The Transport Rule is expected to b e as stri ct as or stricter than

CAIR. A comparison o f CAIR and proposed TR emissions and controls can be found in the weight of evidence section of this document.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 18



## 6. Emission s Inventory

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

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

. M uch of the particulate emissions within the

nonattainment area are transported from the surrounding area, which includes the Pittsburgh

Beaver Valley PM 2.5 nonattainment area, the remainder of southwest Pennsylvania, and states to
the west and south of Pennsylvania

.

The emissions inventory for Libe rty

- Clairton was compiled for sources within the nonattainment area (City of Clairton, Glassport Borough, Liberty Borough, Lincoln Borough, Port Vue Borough). S ources in the emissions inventory include stationary point sources, area/nonroad sources, and m obile sources. The stationary point sources include two major sources (U. S. Steel

Clairton and Koppers)

, two “synthetic minor ” sources (Pennsylvania Electric Coil and Durabond), and one minor source that was formerly classified as a major source (Mid

- Con tinent Coal and Coke). Mid

- Continent was kept in the inventory for consistency between baseline and

future cases. Three additional minor sources were included as PM 2.5 point sources in the modeling inventor y but are not inc luded in this section

.

E missio n s inventories for all source classifications w ere developed for t he Mid

- Atlantic Northeast Visibility Union (MANE

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

and SIPs. The Liberty

- Clairton emissions inventory w as developed from both the re gional

MANE

- VU inventories and projections along with ACHD inventories for stationary point

sources. Emissions given are “actual” values based on pollutant emission factors and throughputs or capacities of each emission source . The emissions values do no t necessarily represent permitted or “allowable” limits.

The year 2002 was used for baseline emissions inventory and 201 4 for the projected inventory for the Liberty

- Clairton area, based on local direct PM 2.5 controls. Regional projections utilized

on

- th e

- books/on

- the

- way (OTB/W) controls through the 2012 timeframe . Since no additional projections are available at the time of this SIP, and since Liberty

- Clairton controls focus on

direct PM 2.5 , regional projections for 2012 were used for precursors and no n

- point PM 2.5 emissions in combination with local projections for 201 4 for stationary point PM 2.5 emissions.

This is discussed more in the previous section (Section 5 ) and in the modeling section (Section 7)

of this SIP.

Regional controls for SO 2 and NO

x in the MANE

- VU inventory were based on CAIR. EPA has proposed the Transport Rule (TR) a s a replacement rule to CAIR, to be effective in 2011. The Transport Rule is expected to b e as stri ct as or strict er than CAIR. A comparison of CAIR and proposed TR emissions and controls can be found in the weight of evidence section of this

document.

Source categories and methodologies used for the emissions inventory are described below. The inventory listings are included in Appendix F, and i nformation on the de velopment of regional baseline and projected inventories are given in Appendix G.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 19

Stationary point sources are sources for which ACHD collect individual emissions

related information. Revisions were made to 2002 point sources data based on newer

estimate s that do not reflect originally submitted data. Additionally, the future case includes revisions that were not part of the regional projections.

Area sources, which are industrial, commercial, and residential sources too small or too

numerous to be hand led individually. These include but are not limited to commercial and residential open burning, architectural and industrial maintenance coatings application and clean

- up, consumer product use, and vehicle refueling at service stations. The regional base line 2002 and projected 2012 emissions were used for area source

emissions. Area sources were given by county in the regional inventories

– emissions were apportioned to the Liberty

- Clairton area based on population counts

. 3

Nonroad sources encompass a d iverse collection of engines, including but not limited to outdoor power equipment, recreational vehicles, farm and construction machinery, lawn and garden equipment, industrial equipment, recreational marine vessels, commercial marine vessels, locomotives , ships, and aircraft. The regional baseline 2002 and projected 2012 emissions were used for nonroad emissions. Similar to area sources, nonroad emissions were apportioned to the Liberty

- Clairton area based on population

.

Mobile sources include passenge r cars and light

- duty trucks, other trucks, buses and motorcycles. This data was compiled by PA DEP for Southwestern PA, with separate estimates for the Pittsburgh

- Beaver Va lley and Liberty

- Clairton areas. For these estimates, 2009 was used as the future projected case and was used in this inventory since

no additional data is available. Mobile source vehicle miles traveled ( VMT ) and

emissions were estimated using GIS and the PennDOT Roadway Management System (RMS). Additional mobile source emissions in formation is given in Appendix F.

Point sources and corresponding revisions used in the ACHD local CALPUFF modeling are provided in Appendix H

. A dditionally, emissions inventories used for Re asonable Further Progress (RFP), including area/nonroad/mobile, have been provided in Appendix H.

Emission s inventory summaries for baseline and future projected cases are shown in Tables 6

- 1

and 6

- 2 on the following page

.

3 Taken from the U.S. Census, year 2000. Liberty

- Clairton represents 1.69% of the total Allegheny County population.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 20

Summary of 2002 Emissions Inventory

Table 6

- 1 below shows emission s totals for the Liberty

- Clairton area for the baseline case (2002). These emissions represent sources only within the 5

- municipality Liberty

- Clairton area, not the larger modeled area.

Table 6

- 1: Baseline 2002 Emissions ( T ons / Y ear)

Liberty

- Clairton Area (2002) PM 2.5 PM 10 SO 2 NO

x VOC NH 3 Stationary Point Sources 2201. 438 2745.678 1358.522 5786.190 432.735 299.714

Area Sources 36.506 151.173 81.962 80.176 336.467 7.416

Nonroad Sources 23.005 29.016 16.170 227.673 119.244 0.078

Mobile Sources 4.918 7.228 12.077 283.422 200.8 41 13.867

Totals 226 5

. 867 2933.095 1468.731 6377.461 1089.287 321.075

Summary of 20 1 4 Emissions Inventory

Table 6

- 2 below shows emission s totals for the Liberty

- Clairton area for the future projected case ( 201 4 ). Similar to the baseline inventory, t hese emissions represent sources only within the 5

- municipality Liberty

- Clairton area.

Table 6

- 2 : Future Projected 2014 Emissions ( T ons / Y ear)

Liberty

- Clairton Area ( 201 4 ) PM 2.5 PM 10 SO 2 NO

x VOC NH 3 Stationary Point Sources 1328

. 785 1881.461 1459.146 5 282

. 002 581

. 492 255

. 456

Area Sources 35.464 157.867 86.464 86.239 307.013 8.176

Nonroad Sources 21.500 27.789 3.034 169.006 83.335 0.093

Mobile Sources 2.749 4.919 1.409 134.079 98.997 14.367

Totals 1388

. 498 2072

. 036 1550

. 053 5671

. 326 1070

. 837 278

. 092Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 21



## 7. Modeling Procedures

7.1

. Design

Allegheny County Health Department (ACHD) followed modeling procedures outlined by the

PM 2.5 Model Protocol, Liberty

- Clairton Nonattainment Area (given in Appendix C ) and by the EPA Modeling Guidance 4 . The modeli ng utilized a combination of regional CMAQ modeling using the MANE

- VU inventory and local CALPUFF modeling using a local revised ACHD inventory. ACHD used the EPA

- preferred Version 5.8 of the CALPUFF /CALMET model.

7.1.1

. Protocol

Deviations or clarific ations made to the modeling design since the development of the protocol

are listed below:

2012 was selected in place of 2009 for the future case MANE

- VU inventory and CMAQ impacts to incorporate additional regional sulfate/nitrate reductions in the 200 9

- 2012

timeframe

The MM5 prognostic data was used for upper air data in CALMET ( NOOBS = 1 mode ) instead of solely using PIT Airport upper air data [airport upper air data is already incorporated into MM5 data ]

Dimensions for the long

- range transport domai n were expanded from 140 km to 150 km, in order to fully utilize the supplied MM5 data and to include additional EGUs in SW PA

and Northern WV

Allegheny County Airport surface meteorological data were included along with PIT Airport data in the 150 km CAL MET meteorological processing

R1, R2, RMAX1, and RMAX2 variables were set to 3.0 m for the 150 km CALMET domain (double the 1.5 m for the 20 km domain values)

-- this was not specified in the model protocol

Spacing for the “CMAQ

- equivalent ” receptor grid in CALPUFF was set to 500 m eters

Instead of shifting the “CMAQ

- equivalent ” grid receptors slightly to the southwest, an additional row of receptors were added within the CMAQ grid area (adding 24 receptors to the bottom of the grid, covering the Clairton nearby area)

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

PM 2.5 , a nd Regional Haze , U.S. EPA, April 2007.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 22

For nitrates, sulfates, crustal (other primary PM 2.5 , or “ OPP ” ), direct RRFs from the CMAQ mo deling were used; for ammonium and water, indirect ( calculated ) values were

used for both baseline and future cases

For the CALPUFF

- modeled primary PM 2.5 , modeled values were combined with CMAQ total carbons (elemental and organic); RRFs were then applied on a total carbon basis

Speciation results for 2003

- 2004 were used for the species reconstruction by composition

CALMET did not support 2001 lan d use data since the development of the protocol, so

USGS NLCD 1992 data was used for land use ( as proposed in the protocol)

An aerial map of the modeling domains is shown below in Figure 7.1 , by MM5 grid, 150 km domain, and 20 km domain.

Figure 7

- 1 : Modeling DomainsLiberty

- Clairton PM 2.5 SIP Revision April 2011 Page 23

A map of the CALMET modeling domains by land use and terrain is shown in Figure 7

- 2 below (note: land use codes are those used by CALMET , not USGS ) . The 20 km x 20 km domain is seen by the darker terrain contours near the center withi n the larger 150 km x 150 km domain

.

Figure 7

- 2 : Modeling Domains by Land Use and Terrain

7.1.2

. Years Modeled

Years modeled by ACHD were 2002 for baseline case and 2014 for future projected case. For the future case, uncorrected source parameters were as given in the 2012 MANE

- VU inventory

. [Accordingly, CMAQ impacts were as given in the 2012 regional results

. ] Revisions to local sources were made according to a 201 4 timeframe, so the resulting future case ACHD inventory is a hybrid of 2012 and 201 4 emissions.

It is assumed that 2012 emissions for uncorrected sources are representative through year 201 4

. Emissions of SO 2 and NO

x are steadily declin ing since 2002 due to regional controls. Only

cr ustal component (fine soil, road dust, or “ other primary particula te ” ) is projected to increase,

but by less than 1% per year. S ince crustal component represents only a small portion of PM 2.5 at Liberty (3% in baseline timeframe ), increases to cru s tal concentrations should be insignificant in comparison to concentrations of other major PM 2.5 components

.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 24



### 7.2

. Methodology

The modeling methodology was based on excess primary PM 2.5 leading to the high concentrations at the Liberty and Clairton FRM monitors. The EPA Modeling Guidance outlines techniques that can be used to model primary PM 2.5

– this section describes the steps used to model the Liberty

- Clairton a rea.

7.2

. 1

. Sources Modeled

Since PM 2.5 in SW PA is composed of a combination of transported and locally

- derived components, a large array of stationary point sources were included in the modeling inventories. The modeling domain included sources within a 150 km x 150 km area, encompassing SW PA along with parts of OH and WV. Emissions used were total “ actual ” primary PM 2.5 (filterable +

cond ensible) for baseline and future projected cases.

The MANE

- VU base and future inventories w ere reviewed for accuracy in coordinates, emissions, and stack parameters. Sources wer e reviewed in comparison to EPA’s National Emissions Inventory ( NEI ) for 2002 , as well as the ACHD 2002 inventory (Allegheny County sources only). Corrections made to the MANE

- VU inventory for use in the corrected modeling are given in Appendix H , along with full inventories.

Regional controls for SO 2 and NO

x in the MANE

- VU inven tory were based on CAIR. EPA has proposed the Transport Rule (TR) a s a replacement rule to CAIR, to be effective in 2011. The Transport Rule is expected to b e as stri ct as or strict er than CAIR. A comparison of CAIR and proposed TR emissions and control s can be found in the weight of evidence section of this

document.

Sources within the 20 km x 20 km domain, centered about the Liberty monitor, were also modeled as more representative source types (lines, volumes, etc.), based on previous modeling

studie s performed by ACHD. Many point (stack) sources also included building parameters to address possible downwash.

7.2.2

. Combination of Impacts

Due to the large number of revisions made to the inventories, ACHD elected to combine modeled impacts from all point sources. This technique allows for proper adjustments for both

near

- field and distant sources, while keeping the integrity of the regional CMAQ results.

The modeled impacts for total carbons were combined using a conservation

- of

- mass technique

tha t avoids double

- counting. Average impacts from the uncorrected MANE

- VU inventory across an “equivalent grid” were subtracted from the CMAQ impacts on a concurrent basis. The corrected ACHD inventory impacts for Liberty and Clairton were then added to the CMAQLiberty

- Clairton PM 2.5 SIP Revision April 2011 Page 25

results, creating sub

- grids of the original CMAQ grid cell. This is shown visually in Figure 7

- 3 on the following page.

CMAQ

- Equivalent + Lib erty, Clairton

Figure 7

- 3: Combination of Modeled Impacts for Total Carbons

7.2.3

. Reconstruction of Species

Modeled total primary PM 2.5 was used to represent total carbon in the modeling due to the analyses shown in the Speciat ion and PMF reports (Appendix E). The s peciation analysis was performed using data in the 2003

- 2005 t imeframe, and carbons represented 74% of the measured excess at Liberty. The carbon

- rich factor from the PMF source apportionment report represents

24% of the total PM 2.5 (equat ing to approximately 5 μg/m3 in the baseline timeframe).

Ammonium, chlorine, and “other” component are also small portions of the localized excess. Although these species are not modeled directly , they are accounted for in the reconstruction of species using the SANDWICH method given in the EPA Modeling Guidance. Reasoning is

lis ted below:

Organic mass by mass balance accounts for all differences between the FRM and other species

Ammonium and chlorine concentrations have been shown to peak simultaneously with carbons, and can likely be attributed to similar sources; controls to carbons would likely apply to associated compounds

“Other” component represents unknown mass from the speciation monitor, likely due to water associated with hygroscopic organics

Furthermore, the recommended method in the EPA Modeling Guidance for recon structing ammonium and water is by indirect calculation (dependent on other species). A directLiberty

- Clairton PM 2.5 SIP Revision April 2011 Page 26

ammonium method using measured/modeled ammonium is included as an option, but it was not used for the following reasons:

There was much uncertainty in the i nve ntories for ammonia and chlorinated compounds

and the particle formation of these compounds within the Liberty

- Clairton area

The CALPUFF modeling was performed for primary PM 2.5 , with no chemical transformation; inclusion of ammonia and/or hydrochloric ac id would require

transformation

CMAQ

- modeled ammonium reductions are based primarily on reductions in associated sulfate and nitrate and would not necessarily apply to excess primary ammonium

Future speciation analyses, reconstruction techniques, and inv entories that incorporate more species may be developed for future SIPs.

The SANDWICH species reconstructions are shown in detail in the A ttainment Demonstration section (Section 8).

7.2.4

. Modeled Source Groups

Sources in the MANE

- VU and ACHD inventor ies were apportioned to source groups for the modeling. A summary of source groups by model input file is provided in Appendix I . Source groups were generally assigned as follows:

Distant sources were grouped by geographic region (distant EGU sources w ere modeled as a specific group)

Near

- field sources within or adjacent to the Liberty

- Clairton area were grouped by facility or source type

A map of sources outside Allegheny County (excluding EGUs) is shown in Figure 7

- 4 for

baseline case with correcte d coordinates. These sources were grouped by county (or by state for OH and WV sources).Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 27 Figure 7

- 4: Map of Modeled Sources Outside Allegheny Co unty (no EGUs)Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 28

A map of EGUs within the modeled area is shown below in Figure 7

- 5 , for basel ine case with corrected coordinates and facility names. These sources represent the majority of PM 2.5 emissions in the tri

- state PA/OH/WV area.

Figure 7

- 5 : Map of Modeled EGUsLiberty

- Clairton PM 2.5 SIP Revision April 2011 Page 29

A map of Allegheny County sources (excluding RRI Energy Cheswick) is shown below in Figure 7

- 6 for baseline case with corrected coordinates. Sources outside the 20 km domain were grouped by geographical region

.

Figure 7

- 6 : Map of Allegheny County Modeled Source Groups and 20 km DomainLiberty

- Clairton PM 2.5 SIP Revision April 2011 Page 30

A map of sources within the 20 km domain is shown below in Figure 7

- 7 for baseline modeled

case with corrected coordinates. Labels are given for selected source groups or areas.

Figure 7

- 7 : Map of Modeled 20 km Domain Sources /GroupsLiberty

- Clairton PM 2.5 SIP Revision April 2011 Page 31

Building parameters were also i ncluded for all point sources within a 2.5 km radius of the Liberty monitor (5 km diameter) and for selected sources within or beyond a 5 km radius (10 km diameter) . A map of near

- field sources within or ad jacent to the Liberty

- Clairton a rea is shown

belo w in Figure 7

- 8 ; sources shown in red included building parameters for stacks that may experience downwash. U

. S

. Steel Edgar Thomson sources (not shown on map) also included building parameters. The Liberty monitoring site is indicated by the white diam ond in the

center.

Figure 7

- 8 : Map of Near

- Field Sources with Building ParametersLiberty

- Clairton PM 2.5 SIP Revision April 2011 Page 32

7.2.5. Emission s Totals

Total modeled primary PM 2.5 emissions by area (or group) for the corrected baseline and future

cases are shown in T able 7

- 1 below.

Table 7

- 1: Modeled Emissions Totals

Source Group /Area Baseline 2002 Primary PM 2.5 (tons ) Future 2014

Primary PM 2.5 (tons ) Allegheny Co.* 873 927 Armstrong Co. 54 66

Beaver Co. 250 278

Butler Co. 321 339 EGUs (Distant) 51779 27934 EGUs (Near

- Field)** 746 691 Fayette Co. 115 145

Greene Co. 146 157

Lawrence Co. 529 718

Ohio 372 367 Washington Co. 120 146

Westmoreland Co. 241 286

U

. S

. Steel Clairton 218 6 1304

U

. S

. Steel Edgar Thomson 961 912 West Virginia 7570 6435

TOTAL 66263 40705

* Allegheny Co. without U

. S

. Steel E dgar T homson , U

. S

. Steel Clairton, and RRI Energy Cheswick

** Near

- field EGUs include RRI Energy Elrama and Allegheny Energy Mitchell plants

7.2.6

. Combination of Impacts

For use in the calculation of design values, locally

- m odeled primary PM 2.5 impacts from CALPUFF were combined with CMAQ modeled results. For annual results, impacts were combined on a quarterly average basis. For the 24

- hour results, impacts were combined on an hourly basis, and daily averages of the hourly values were used for the high

- day analysis described later in this section. [Hourly impacts were used for the daily averages to ensure alignment of the 24

- hour periods with no time differences between Local Standard Time (LST) and Greenwich Mean Time (GM T); MM5 prognostic data was formatted in GMT.]

CMAQ modeled values are given as one value per species for any given time period. Grid averages from the CALPUFF modeling were based on the average of all receptors within aLiberty

- Clairton PM 2.5 SIP Revision April 2011 Page 33

selected grid

, i .e., the CALPUFF

- modeled “ CMAQ

- equivalent ” value for any time period is the average of all 600 receptors. For the nearby receptor grids, the Liberty value is an average of 40 receptors and the Clairton value is an average of 51 receptors.

7.2.7. Aggregation of Source Gr oups and Domains

Local CALPUFF modeling was performed on a source group basis in two modeling domains (long

- range 150 km and near

- field 20 km). Impacts needed to be combined accordingly for each receptor grid and modeled case (baseline or future) prior t o combination with CMAQ values. The following steps were taken to combine impacts from model output files:

1) The post

- processor CALSUM was used to combine outputs from different source groups in each modeled domain

2) The post

- processor CALPOST was used to g enerate receptor impacts from the CALSUM files by averaging period (quarterly or hourly) for each domain

3) Receptor impacts from the 150 km and 20 km domains were summed via spreadsheet

4) Combined

- domain receptor impacts were then averaged by time period (qu arterly or daily)

5) Steps 1 and 2 were repeated for each grid and modeled case

For example, to generate baseline receptor impacts from the Liberty nearby grid for use in the annual test, CALSUM was used to combine the source group output files for each do main. Receptor impacts were then generated by CALPOST for each domain on quarterly average bases. The average receptor impacts from the 150 km and 20 km runs were summed via spreadsheet for each quarter. The averages of all receptors by quarter were the n used as the Liberty Nearby quarterly values for baseline case.

[Note: The two nearby grids were actually run as one grid in the model files in order to conserve run time. Impacts were separated in the post

- processing (Liberty nearby receptors: 1

- 40,

C lairton nearby receptors: 41

- 91).]

Model input/output and post

- processing files have been given in Appendix I (or on the accompanying DVD).

7.2.8. Combination of Annual Impacts

For the annual basis, quarterly average CALPUFF

- modeled “ CMAQ

- equivalent ” v alues were first subtracted from the total carbon (elemental + organic) quarterly averages from the CMAQ modeling. Quarterly averages from each of the nearby areas (Liberty and Clairton) were thenLiberty

- Clairton PM 2.5 SIP Revision April 2011 Page 34

added to the result. This formula was used for both basel ine and future projected cases. The combined impacts from each area are then used to generate Relative Response Factors (RRFs)

for total carbons.

7.2.9. Combination of 24

- Hour Impacts

Using the same methodology as the annual combination of impacts but on a different time scale, hourly CALPUFF

- modeled “ CMAQ

- equivalent ” averages were subtracted from each CMAQ hourly total carbons value. Hourly averages from the nearby runs were then added to the result, and daily averages (midnight

- to

- midnight 24

- hour pe riods) were created from the hourly

combinations.

For use in the 24

- hour test, the top 25% of high modeled days per quarter were used for RRFs. Therefore, high days by sum of all modeled species were ranked by quarter. [Full 24

- hour combination of impac ts is given electronically on the DVD.] The top 23 days in each quarter were then used to generate average high

- day modeled values for the species used for direct RRFs (sulfate, nitrate, OPP, and carbons).Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 35



## 8. Attainment Demonstration

8.1

. Monitore d Data Assumptions

The following assumptions were made for the Liberty and Clairton monitored data for use in the

annual and 24

- hour standard attainment tests.

Liberty speciation data is assumed to be representative of both the Liberty and Clairton

monit ored areas . T he Liberty species compositions are representative of Clairton, but at smaller overall concentrations. Liberty species compositions are therefore used with Clairton weighted FRM values in the design value calculation.

Liberty speciation dat a is available from 4 th quarter 2003 through 4 th quarter 2004. It is assumed that these compositions are representative of the entire baseline timeframe of

2000

- 2004.

Liberty speciation data recovery for 4 th quarter 2003 is 67%, below the recommended

rec overy percentage of 75%. Since compositions are similar to that of 4 th quarter 2004, and for a more robust speciation data set, it has been included in the species composition

calculations.

Clairton FRM data i s available for 2001

- 2004. It is assumed tha t these years are also representative of the year 2000, which is excluded from the weighted FRM values.

No 4 th

- of

- July peaks or other valid anomalies are evident in the FRM and speciation data. All data has been included in the design value calculations.

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

- calculated EPA speciation SMAT/MATS data set.



### 8.2

. Annual Attainment Test Methodology

Speciated Modeled Attainment Test (SMAT) methodolo gy for the annual standard is given in the EPA Modeling Guidance. 5 Species reconstruction is based on the SANDWICH ( s ulfate,

a djusted n itrate, d erived w ater, i nferred c arbonaceous material balance approac h ) technique. The steps for the annual SMAT are li sted below:

Calculate 5

- year weighted FRM quarterly averages . This is the 3

- year average of the

2000

- 2002, 2001

- 2003, and 2002

- 2004 3

- year quarterly averages. This is done for the Liberty and Clairton FRM monitored values.

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

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

- Clairton PM 2.5 SIP Revision April 2011 Page 36

Calculate retained nitrate (N O3

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

- calculated by EPA. The formula used for retained

nitrate is shown below, as given in the EPA Modeling Guidance :

Calculate quarterly averages of non

- dependent spe cies . Averages for nitrate, sulfate, other primary PM 2.5 (OPP), and elemental carbon, and concurrent FRM values are calculated. Quarterly averages for measured organic carbon are also calculated for comparison to an organic carbon minimum (or OC floor ). Quarterly averages for DON are

also calculated for use in the retained ammonium calculation.

Calculate quarterly averages of retained ammonium (NH4

r ) . Averages for retained ammonium are calculated from quarterly sulfate, nitrate, and DON averages. The

f ormula is given below , as given in the EPA Modeling Guidance :

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

Guide :

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

PBW = {202048.975

- 391494.647 *S

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

- 155.335 *(N**1.5)

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

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

- 447.123 *(S**2.5)

- 507.157 *(S**1.5)*N

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

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

- 18.649 *(N**3)

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

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

+ 95413.122 *(A**3 )} * (SO4+NO3r+NH4r) NH4

r = DON*SO4 + 0.29*NO3

rLiberty

- Clairton PM 2.5 SIP Revision April 2011 Page 37

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

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

measured.

Calculate quarterly species compositions; app ly to weighted quarterly FRM averages. This is done by calculating fractions of the total (minus 0.5 passive blank mass) by species, then recalculating species concentrations based on weighted FRM values.

Calculate quarterly Relative Response Factors (RR Fs) from modeling. For this demonstration, direct RRFs are calculated from baseline and future CMAQ modeling for sulfate, nitrate, and OPP. The combined ACHD modeling is used to generate total carbons RRFs (applied to sum of elemental and OCM mb ).

Calcul ate future quarterly species averages from RRFs, re

- calculate ammonium and

PBW. The RRFs reduce the sulfate, nitrate, OPP, and carbons from the weighted baseline case values. Future case ammonium and PBW is calculated from the new quarterly

averages.

Ca lculate the future design value. This is done by adding the future case species by quarter (plus 0.5 blank) and averaging the quarterly future FRM values, r ounded to the nearest tenth for comparison to the annual standard. For an area with strong

concent ration gradients such as the Liberty

- Clairton, ACHD followed EPA Mo deling

G uidance by using a one

- cell (single

- site) analysis in place of a spatially

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



### 8.3

. 24

- Hour Attainment Test Methodology

The Speciated Modeled Attainment Test (SMAT) for the 24

- hour standard uses the same methodology as the annual standard for reconstruction of species and RRFs. But, modeled and observed concentrations are based on specific high

- day quarterly averag es inste ad of overall averages, based on EPA Modeling Guidance.

Indentify observed (monitored) high days in baseline timeframe . This is done by selecting the highest day in each quarter (for each FRM monitor) that is less than or equal

to the 98 th

- percentile va lue for the corresponding year (2000

- 2004). This method focuses on high days that represent seasonal highs rather than overall maximums.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 38

Calculate quarterly species compositions for speciation high days . This is done using the same technique as the annu al species compositions, but the quarterly averages are based on the highest 25% (3 samples) of speciation samples by overall concentration.

Calculate weighted species compositions for baseline high days . This is done by using the quarterly species fract ions for each of the high days monitored observed days. The end results are quarterly species compositions for each year (2000

- 2004).

Calculate quarterly Relative Response Factors (RRFs) for high days from modeling. The high modeled days are identified after summing all components, included the combined carbons from the ACHD modeling. The top 25% (23 days) by quarter are then averaged for sulfate, nitrate, OPP, and carbons. RRFs are calculated from the baseline and future

modeled results.

Calculate fu ture high days from RRFs; re

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

calculated from the f

uture sulfate, nitrates.

Calculate future design value. Identify future 98 th

- percentile days, calculate the 5

- year weighted average of the projected 98 th

- percentile days. Similar to the annual weighted FRM value, the weighted average is the 3

- year avera ge of the 2000

- 2002, 2001

- 2003, a nd

2002

- 2004 3

- year averages, r ounded to the nearest integer for comparison to the 24

- hour

standard.



### 8.4

. Annual Standard Test Results

A summary of the annual design value calculations for Liberty is given in Tables 8

- 1 to 8

- 4

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

Baseline quarterly compositions are calculated by the sum of the maj or species. RRFs are calculated by ratios of the modeled future case to baseline case results. The future case results are then calculated by multiplying the baseline results by the corresponding RRF by species.

Note: Attainment tests results using reg ional modeling data without Liberty

- Clairton local modeling showed nonattainment for both 2009 and 2012. Therefore, a local modeling analysis was necessary in order show compliance for this SIP.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 39

Table 8

- 1: Baseline Quarterly Compositions

– Liberty Annu al

QTR Total PM 2.5 Blank Organic Mass (by Balance) Elemental

Carbon Total

Carbon Sulfate Nitrate Crustal (OPP) Ammonium Water

1Q 18.2778 0.5 4.8986 1.5001 6.3987 5.0112 1.9749 0.6142 2.2179 1.5608

2Q 22.0970 0.5 6.4918 3.0769 9.5687 6.3429 0.0000 0.6637 2.2698 2.7519

3Q 24.4259 0.5 8.6776 3.0518 11.7294 6.8741 0.0000 0.6204 2.1040 2.5980

4Q 19.1917 0.5 7.8132 2.6732 10.4864 3.9615 0.4413 0.5301 1.5890 1.6834

AVG 20.9981

Table 8

- 2: Modeled Relative Response Factors (RRFs)

– Liberty Annual

QTR Total

Carbon Sulfate Nitrate Crustal (OPP)

1Q 0.6281 0.8418 0.9662 1.0609

2Q 0.5840 0.5897 0.8604 1.1010

3Q 0.5911 0.5581 0.8319 1.1148

4Q 0.6750 0.8021 0.9216 1.0777

Table 8

- 3: Future Projected Quarterly Compositions

– Liberty Annual

QTR Total PM 2.5 Blank Total
Carbon Sulfate Nitrate Crustal (OPP) Ammonium Water

1Q 14.5383 0.5 4.0188 4.2186 1.9081 0.6517 1.9384 1.3027

2Q 13.5201 0.5 5.5883 3.7401 0.0000 0.7307 1.3384 1.6227

3Q 14.5860 0.5 6.9336 3.8365 0.0000 0.6916 1.1743 1.4500

4Q 14.3708 0.5 7.0779 3.1774 0.4067 0.5713 1.2898 1.3477

AVG 14.2538

Table 8

- 4: Liberty Annual Design Values

Case Year Value

Baseline 2002 21.0
Future Projected 201 4 14.3Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 40

A summary of the annual design value calculations for Clairton is given in Ta bles 8

- 5 to 8

- 8

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

Table 8

- 5: Baseline Quarterly Compositions

– Clairton Annu al

QTR Total PM 2.5 Blank Organic Mass (by Balance) Elemental

Carbon Total

Carbon Sulfate Nitrate Crustal (OPP) Ammonium Water

1Q 13.9271 0.5 3.6998 1.1330 4.8328 3.7848 1.4916 0.4639 1.6751 1.1788

2Q 17.3044 0.5 5.0513 2.3941 7.4453 4.9353 0.0000 0.5164 1.7661 2.1413

3Q 20.9413 0.5 7.4138 2.6073 10.0211 5.8730 0.0000 0.5300 1.7976 2.2196

4Q 14.7063 0.5 5.9382 2.0317 7.9700 3.0109 0.3354 0.4029 1.2077 1.2794

AVG 16.7198

Table 8

- 6: Modeled Relative Response Factors (RRFs)

– Clairton Annual

QTR Total

Carbon Sulfate Nitrate Crustal (OPP)

1Q 0.8023 0.8418 0.9662 1.0609

2Q 0.6714 0.5897 0.8604 1.1010

3Q 0.6008 0.5581 0.8319 1.1148

4Q 0.7279 0.8021 0.9216 1.0777

Table 8

- 7: Future Projected Quarterly Compositions

– Clairton Annual

QTR Tota l PM 2.5 Blank Total
Carbon Sulfate Nitrate Crustal (OPP) Ammonium Water

1Q 11.9447 0.5 3.8773 3.1862 1.4412 0.4922 1.4640 0.9839

2Q 11.2818 0.5 4.9991 2.9101 0.0000 0.5686 1.0414 1.2626

3Q 12.6319 0.5 6.0211 3.2778 0.0000 0.5909 1.0033 1.2388

4Q 11.464 5 0.5 5.8017 2.4149 0.3091 0.4342 0.9803 1.0243

AVG 11.8307

Table 8

- 8: Clairton Annual Design Values

Case Year Value

Baseline 2002 16.7
Future Projected 201 4 11.8Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 41



### 8.5

. 24

- Hour Standard (65 μg/m3) Test Results

A summary of the 24

- hour de sign value calculations for Liberty is given in Tables 8

- 9 to 8

- 13

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

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

Table 8

- 9: Baseline Quarterly High Days

– Liberty 24

- Hour

QTR 2000 2001 2002 2003 2004

1Q 46.7 61.9 50.8 60.4 64.2

2Q 64.2 63.9 58 .2 66.6 59.6

3Q 48.6 56.4 59.9 60.8 64.2

4Q 60.3 57.5 56.8 64.8 68.5

Table 8

- 10: Baseline Quarterly Compositions

– Liberty 24

- Hour

QTR Total PM 2.5 Blank Organic Mass (by Balance) Elemental

Carbon Total

Carbon Sulfate Nitrate Crustal (OPP) Ammonium Wat er

1Q 23.7667 0.5 7.8059 3.0633 10.8692 5.5200 1.7867 0.7400 2.5881 1.7627

2Q 48.8000 0.5 14.5477 7.4633 22.0110 14.0533 0.0000 1.0367 5.2700 5.9290

3Q 42.6333 0.5 17.5372 6.1533 23.6905 10.1200 0.0000 0.7300 3.3396 4.2532

4Q 43.0833 0.5 21.5537 7.2700 28.8237 6.8633 0.3217 1.0167 2.6670 2.8910 (Note: Total carbon is the total of organic carbon and elemental carbon.)

Table 8

- 11: Modeled Relative Response Factors (RRFs)

– Liberty 24

- Hour

QTR Total

Carbon Sulfate Nitrate Crustal (OPP)

1Q 0.5451 0.8408 1.1309 1.1286

2Q 0.5046 0.4952 1.6330 1.1917

3Q 0.5233 0.5233 1.1323 1.1282

4Q 0.5597 0.6503 1.1297 1.1675

Table 8

- 12: Future Projected Quarterly High Days

– Liberty 24

- Hour

QTR 2000 2001 2002 2003 2004

1Q 34.2 45.3 37.2 44.2 47.0

2Q 33.2 33.1 30 .1 34.5 30.9

3Q 25.8 29.9 31.7 32.2 34.0

4Q 36.7 35.0 34.6 39.5 41.7

Table 8

- 13: Liberty 24

- Hour Design Values

Case Value

Baseline 6 4
Future Projected 42Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 42

A summary of the 24

- hour design value calculations for Clairton is given in Tables 8

- 14 to 8

- 18

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

Table 8

- 14: Baseline Quarterly High Days

– Clairton 24

- Hour

QTR 2000 2001 2002 2003 2004

1Q

--- 22.9 20.2 24.1 16.7

2Q

--- 44.5 50.4 58.8 26.3

3Q

--- 36.5 39.8 37.0 39.8

4Q

--- 31.5 35.0 21.1 26.4

Table 8

- 15: Baseline Quarterly Compositions

– Liberty 24

- Hour (by perce ntage, applied to Clairton

high days)

QTR Total PM 2.5 Blank Organic Mass (by Balance) Elemental

Carbon Total

Carbon Sulfate Nitrate Crustal (OPP) Ammonium Water

1Q 23.7667 0.5 7.8059 3.0633 10.8692 5.5200 1.7867 0.7400 2.5881 1.7627

2Q 48.8000 0.5 14.5477 7.4633 22.0110 14.0533 0.0000 1.0367 5.2700 5 .9290

3Q 42.6333 0.5 17.5372 6.1533 23.6905 10.1200 0.0000 0.7300 3.3396 4.2532

4Q 43.0833 0.5 21.5537 7.2700 28.8237 6.8633 0.3217 1.0167 2.6670 2.8910 (Note: Total carbon is the total of organic carbon and elemental carbon.)

Table 8

- 16: Modeled Rela tive Response Factors (RRFs)

– Clairton 24

- Hour

QTR Total

Carbon Sulfate Nitrate Crustal (OPP)

1Q 0.7555 0.8018 1.0187 1.0702

2Q 0.5555 0.5198 1.0447 1.1634

3Q 0.5147 0.5641 0.9517 1.1445

4Q 0.6292 0.5828 1.0972 1.0999

Table 8

- 17: Future Projected Quarterly High Days

– Clairton 24

- Hour

QTR 2000 2001 2002 2003 2004

1Q

--- 18.4 16.3 19.4 13.5

2Q

--- 24.7 27.9 32.5 14.7

3Q

--- 19.8 21.6 20.1 21.6

4Q

--- 20.1 22.3 13.5 16.9

Table 8

- 18: Clairton 24

- Hour Design Values

Case Value

Baseline 49

Fut ure Projected 27Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 43



### 8.6

. Lincoln Area Analysis

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

monitored and modeled relative resp onse ratios within spatial fields across the area. 6 The Liberty and Clairton Monitors are part of a complete network for Allegheny County

– according to monitoring network guidance, there are no “unmonitored ” areas. However, for a more complete analysis, ACHD examined all locations between the Libe rty monitor site and the U. S. Steel Clairton Plant, referred to as the “Lincoln area”, which comprises portions of Lincoln, Liberty, and Glassport.

The Lincoln area corresponds to the area downwind from the Cl airton plant, since wind is predominantly from the southwest in the area. A large portion of the area is not suitable as a neighborhood

- scale location for monitoring PM 2.5 because it does not represent a highly populated area and is source

- oriented, i.e., within an “area of influence” of the Clairton plant.

Monitored data since 1999 has shown that Liberty considerably exceeds monitored data in surrounding areas (including Clairton, North Braddock, Forward, and South Park) on both

annual and 24

- hour bases. Table 8

- 19 below shows the projected design values for Liberty, Clairton, and North Braddock (the nearest current PM 2.5 site outside the Liberty

- Clairton area).

All monitors are below the standards in the future case.

Table 8

- 19 : Future C ase D esign V al ues

Site Annual 24

- Hour Liberty 14.3 4 2
Clairton 11.8 27

North Braddock* 14.3 33

* North Braddock values are taken from the Pittsburgh

- Beaver Valley SIP

Any flat

- terrain interpolation from Liberty to other areas would show a decreasing conc entration gradient. In the case of the Liberty

- Clairton area, terrain and meteorology can strongly affect

concentrations. Supplemental modeling was performed to examine the specific reduction s of impacts in the Lincoln area . Modeled contour plots of the PM 2.5 impact reductions were generated as follows:

Create a receptor grid at 250 m eter spacing for a dense grid covering all hills and valleys

in the Lincoln Area

6 The Modeled Attainment Test Software (MATS) was developed by EPA to automatically calculate design values and interpolate for unmonitored areas. However, MATS does not recognize terrain and meteorology

- driven scenarios that affect the Liberty

- Clairton Area. Furthermore, testing of MATS version 2.2.1 showed inco nsistent results with methodology given in the EPA Modeling Guidance. Therefore, MATS was not used in this attainment

demonstration.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 44

Model all sources in the 20 k ilometer domain for base line and future cases

P lot the perce nt reduction from the baseline case impacts on an aerial map to examine

annual and 24

- hour high percent reductions throughout the Lincoln area

The rece ptor grid used for the Lincoln a rea is given below in Figure 8

- 1. Receptors are shown as the yellow do ts at 250 m spacing throughout the Lincoln area.

Figure 8

- 1 : Receptor Grid for the Lincoln AreaLiberty

- Clairton PM 2.5 SIP Revision April 2011 Page 4 5

A contour plot of annual impact reduction s for the Lincoln Area is shown below in Figu re 8

- 2

. The contour labels indicate the percent reduction, which is calculated as the baseline minus future concentration, divided by baseline concentration (in %). The contours are color

- coded yellow

- to

- red, with yellow as the lowest reductions and red as the highest.

Figure 8

- 2 : Annual Impacts by Percent Reducti on in L incoln Area

The attainment test shows that the Liberty site is being reduced from a baseline weighted annual concentration of 21.0 μg/m3 to 14.3 μg/m3 due to modeled reductions of 45% (baseline to future). While actual monitored concentrations are unknown in the Lincoln Area, the contoursLiberty

- Clairton PM 2.5 SIP Revision April 2011 Page 46

show percent reductions throughout the Lincoln area that are equal to or greater than the reductions at the Liberty monitor site.

Further examination of the annual reductions throughout area is shown in Figure 8

- 3

.

Figure 8

- 3 : Annual Percent Reductions with Descriptions

The largest localized reductions occur near the site of Mon Valley Transportation Center, which was shut down in the future modeled case. The widespread reductions throughout the downwi nd

area are primarily due to the proposed new configuration at the U. S. Steel Clairton Plant. Additional reductions throughout the area can be due to regional decreases in emissions from sources outside the Liberty

- Clairton area. Liberty Site

Reductions here due

to shutdown of Mon
Valley Transportation

Center Reductions throu ghout
downwind area primarily
due to proposed future configuration at U. S. Steel

Clairton P lant Additional reductions can be

due to decreases in

emissions from surrounding
and background sources

Clairton

PlantLiberty

- Clairton PM 2.5 SIP Revision April 2011 Page 47

A contour plot of 24

- ho ur impact reduction s for the Lincoln Area is shown below in Figure 8

- 4

.

Figure 8

- 4 : 24

- Hour Impacts by Percent Reduction in Lincoln Area

The attainment test shows that the Liberty site is being reduced from a baseline weighted concentration of 64 μg/ m3 to 42 μg/m3 due to modeled reductions of 50% (baseline to future). Similar to the annual percent reduction contours in Figure 8

- 2, the 24

- hour contours show percent reductions throughout the Lincoln area that are equal to or greater than the reductions at the Liberty monitor site.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 48



### 8.7

. Model Performance

Model performance for regional CMAQ modeling has been performed by the New York State Department of Environmental Conservation ( NYSDEC ) and is included in Appendix K of this

SIP

. The CMAQ model perf ormance examined prediction for major species throughout the

modele d Mid

- Atlantic/Northeastern U.S

. For the Liberty

- Clairton demonstration, the combined CMAQ/CALPUFF local modeling was examined for appropriateness in predicting the local

excess component.

ACHD analys i s has shown that localized excess in Liberty

- Clairton is dependent on nighttime temperature inversions within complex terrain. 7 The modeled concentrations should therefore represent a diurnal trend similar to the monitored data. P lot s of av erage hourly combined CMAQ /CALPUFF modeled concentration s compared to monitored concentrations (measured by the Liberty continuous TEOM) f or baseline 2002 are given below in Figures 8

- 5 and 8

- 6

, by

year

- round and quarter ly averag e bases, respectively.

Figure 8

- 5 : Hourly Average Liberty Modeled and Monitored PM 2.5 (TEOM), Baseline 2002,

Year

- Round Basis

7 Inversion data for 2002 is shown in Appendix A.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 49

Figure 8

- 6 : Hourly Average Liberty Modeled and Monitored PM 2.5 (TEOM), Baseline 2002, Quarterly Basis

The combine d CMAQ/CALPUFF model simulation effectively recognized the diurnal trends in hourly data in a l l four quarters , with the best predicted hourly averages occurring in the 2 nd and

3 rd quarters . Differ ences in overall concentration show that the mo del overpred icted for all hours

– however, the modeled concentrations are used for relative reductio ns from the base to future

case instead of absolute comparison to the NAAQS.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 50

In order to compare base to future case modeled diurnal trends, average hourly combined

C MAQ/CALPUFF modeled Liberty concentrations for base line and future cases are shown

below in Figure s 8

- 7 and 8

- 8

, by year

- round and quarter ly bases

.

Figure 8

- 7 : Hourly Average Liberty Mode led Base line and Future Cases, 2002 and 201 4

, Year

Round BasisLiberty

- Clairton PM 2.5 SIP Revision April 2011 Page 51

Figure 8

- 8 : Hourly Average Liberty Modeled Base line and Future Cases, 2002 and 201 4

, Quarterly Basis

The before and after model results show that the future case controls lower concentrations overall, with the largest reductions occurring during the nighttime inversion periods (indicated by the longer dotted high

- low lines) in all four quarters

. These plots demonstrate that the

modeled response to the future control measures is effectively reducing the local excess th at has

been observed in hourly monitored data

.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 52

Combined CMAQ/CALPUFF m odeled results were also compared on a daily basis to the FRM results from 2002. Modeled daily averages and FRM values for Liberty in 2002 are shown below in Figure 8

- 9 on a time

- sca le basis.

Figure 8

- 9 : Daily Average Liberty Modeled and Monitored (FRM), Baseline 2002

Daily comparisons show that the modeled and monitored high days do not show an exact correlation, but similar high and low days do occur within each quarter (sep arated by the dotted lines). The long

- term design value is based on quarterly reductions from each quarter, and the

24

- hour design value is based on quarterly high day reductions. Therefore, the modeled concentrations are adequate for projecting relative reductions of monitored results on a quarterly

basis.

The EPA Modeling Guidance recommends performance statistics for use in operational

evaluation of the modeled results. E quations for the Mean Fractional Bias (MFB) and Mean Fractional Error (MFE) metr ics are given on the following page

.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 53

Mean Fractional Bias (%)

Mean Fractional Error (%)

These equations were used to test the accuracy of the modeled results compared to actual monitored data for the 2002 baseline case. “Goal” represents a good statistical relationship, while “criteria” represents average results (limits were used in regional model evaluations, given

in the EPA Modeling Guidance). Comparison was done for total PM 2.5 , since actual monitored results from the speciation monitor wer e not available for 2002.

Table 8

- 2 0 : Statistics for the M odeled D aily Liberty A verages C o mpared to the Liberty

FRM Values

, Y ear

- R ound and by S eason , 2002

DAILY Results Mean

Fractional

Bias (MFB) Mean

Fractional

Error (MFE)

1 st Quarter 35.99% 45.7 6%

2 nd Quarter 7.59% 39.56%

3 rd Quarter 12.25% 30.52%

4 th Quarter 45.91% 51.13%

Year

- Round 25.43% 41.73%

GOAL ≤ ± 30% ≤ 50%

CRITERIA ≤ ± 60% ≤ 75%

Positive bias indicates that the model over

- predicted for all seasons, with the 2 nd and 3 rd quarters performing the best (lowest) for bias and error. Year

- round, 2 nd quarter, and 3 rd quarter statistics

fell within the goal range, indicative of good results. 1 st and 4 th quarter results fell within the criteria range, indicative of average results.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 54

Figure 8

- 10 shows a “soccer plot” that visually shows the daily statistics as data points within the goal and criteria ranges (red and blue boxes, respectively). Year

- round, 2 nd quarter, and 3 rd
quarter points lie within the “goal” of the soccer plot.

Figure 8

- 10 : Liberty Daily Model Statistics, Baseline 2002Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 55

Figures 8

- 11 and 8

- 1 2 show correlation plots with l inear regression statistics for year

- round and

seasonal combined CMAQ/CALPUFF Liberty daily modeled and monitored FRM results. The

dotted red 1:1 lines represent perfect correlation.

Figure 8

- 11 : Liberty Modeled and Monitored Correlation, Daily Ave rages, Baseline Case 2002,

Year

- Round BasisLiberty

- Clairton PM 2.5 SIP Revision April 2011 Page 56

Figure 8

- 1 2 : Liberty Modeled and Monitored Correlation, Daily Averages, Baseline Case 2002, Quarterly BasisLiberty

- Clairton PM 2.5 SIP Revision April 2011 Page 57

Similar to bias and error results, 1 st and 4 th quarter data (along with year

- round) showed the best correlation between daily modeled and monitored results.

Table 8

- 21 : S tatistics for the M odeled H ourly Liberty V alues C ompared to Liberty TEOM

Values

, Y ear

- R ound and by S eason , 2002

HOURLY Results Mean

Fr actional

Bias (MFB) Mean

Fractional

Error (MFE)

1 st Quarter 44.74% 69.56%

2 nd Quarter 4.90% 52.85%

3 rd Quarter 16.66% 48.80%

4 th Quarter 43.35% 83.61%

Year

- Round 28.62% 63.69%

GOAL ≤ ± 30% ≤ 50%

CRITERIA ≤ ± 60% ≤ 75%

The hourly statistics show shows that the model was less accurate on an hourly basis than a daily basis, but the hourly results do achieve goal for bias and criteria for error on a year

- round basis.

Seasonal result s also show similar trends to the daily results, with 2 nd and 3 rd quarters producing

the best statistics and 1 st and 4 th quarters producing the worst statistics.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 58



## 9. Reasonably Available Control Technology and Measures

The r equirements for R easonably A vailable C ontrol T echnology (RACT) and reasonably available control measures (RACM) for each PM 2.5 nonattainment area, require a demonstrati on that the agency has adopted all reason ably available control measures, including RACT for stationary sources

, ne cessary to demonstrate attainment as expeditiously as practicable and to meet any RFP requirements. In determining whether a particular emission reduction measure or set of measures must be adopted as RACM, the agency must consider the cumulative impact o f implementing the available measures. Potential measures that are reasonably available considering technical and economic feasibility must be adopted as RACM if, considered collectively, they would advance the attainment date by one year or more.

Prim ary PM 2.5 is the pollutant of conc ern in the Liberty

- Clairton non attainment area. As presented earlier in this SIP, the area is too small, and conditions are not appropriate for SO 2 or NO

x from sources located within the non attainment area to be able to c onvert to PM 2.5 . So RACM, including RACT, was reviewed for primary PM 2.5 only.

Most of the emission reduction s to reach attainment are depende nt on the construction of new low emission quench towers at the U

. S

. Steel Clairton Plant

. The n ew quench tow er s will result

in a decrease of over 7 00 tons per year of primary PM 2.5 . The batteries and quench towers have already engaged reasonabl y available control technology, and the entire five

- mu nicipal Liberty

Clairton region, beyond the batteries and quench towers, total less than 200 tons per year of primary PM 2.5 . No combination of further controls in addition to those already imposed on the area would advance the attainment date by one year. ACHD has, therefore, adopted RACT and

RACM as defined for this PM 2.5 SIP.

There are t wo stationary major sources : U. S. Steel Clairton Plant and Koppers Industries

. Mid

Continent Coal and Coke Company was listed as a major source in 2000

- 2002 and is included

he re but has since been classified as a minor source

. Al l three sources are required to have operating permits. There are seven other stationary minor sources required to have operating permits in the same area. A unit

- by

- unit analysis of all the RACT for the Liberty

- Clairton area

PM 2.5 is found in A ppendix B

.

T he sole purpose of this RACT /RACM analysis is for determining whether there were additional reasonable controls available that could advance the attainment date by one year. These reviews

should not and cannot be used by any source to satisfy any RACT analysis required by that source in a present or future permitting project.

A. RACT at U

. S

. Steel Clairton Plant and A lternative s C onsidered

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

- Clairton area.

Both U

. S

. Steel and ACHD separately reviewed the PM 2.5 e missions units for the facility and found them to be satisfactory for this RACM demonstration.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 59

As part of the Clairton Plant installation permit appli cation for C Battery

, U. S. Steel performed a

Best Availa ble Control Technology (BACT) analysis for all the affected emission units. The

Clairton Plant batteries are of the conventional by

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

- by

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

- product coke oven plant.

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

- 3, 13

- 15, 19

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

For the new Q ue nch T owers C , 5 A , and 7 A

, double baffles are RACT v ersus alternative shorter quench towers with single baffles. Coke dry quenching (CDQ) was considered but foun d unacceptable for this project due to available space and cos t. This was the same conclusion on the other remaining quench towers. Other options were reviewed but would required extensive construction and installation costs. Included in this review were a “wet Low Emission Quench (LEQ), ” a “ThyssenKrupp EnCoke Wo rld Steel, Bochum Coke Stabil ization Quenching (CSQ)

process
, ” a “Kress Indirect Cooling (KIDC) system, ” and others.

Alternatives to such pushing emissions control are the use of a coke side shed enclosure vented

to a control device or a mobile capture a nd control unit. However, the shed system is too costly and the mobile capture is not technically feasible for this SIP. For battery process upsets, the atmospheric venting of raw coke oven gas through by

- pass/bleeder stacks is first passed through

a fla re system. The alternatives to this are to use either regenerative thermal oxidation or

catal ytic thermal oxidation; however, these alternatives are too costly to be feasible for this SIP. Similarly, the impact s from the emissions of Boiler #1, Boiler #2 , R1 Boiler, R2 Boiler, T1 Boiler, T2 Boiler, and the Desulfurization Plant Afterburner do not warrant additional control.

B. RACT a t Koppers Industries, Inc. and A lternatives C onsidered

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

For the t ar r efining p rocess
, gases from the fume vents, pressure reliefs, ejectors, chiller, and condensate separator a re manifolded together and burn ed in the eight process heaters. As

alternative controls

, the fumes could be fla red or catalytically oxidized

– but n either of the two

alternatives would result in added emission reductions. Flaring wo uld be less efficient and

cat alytic oxidation is more costly, so they are unacceptable alternatives.

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

-

jet baghouse is used to control particulate emi ssions from the two units. As an

alternative

, a wet scrubber could be utilized, but there would be an undesirable wastewater disposal problem without gaining any emission reduction advantage.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 60

C. RAC T at Mid Continent Coal and Coke Co. and A lternatives C on sidered

Mid

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

the U. S. Steel Clairton Plant

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

The only emissions of interest from this plant are unpaved roadways. As alternatives, the roadway areas could ha ve dust suppressant or watering; however

, the emission reduction benef it from these alternatives is minimal because the amounts are small from the onset and the grounds tend to retain significant moisture.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 61



## 10

. Reasonable Further Progress

This section explains and demonstrates reasonable further progress (RFP) by achiev ing incremental emission reductions required until the area known as the Liberty

- Clairton

nonattainment area in Allegheny County reaches attainment of the federal PM 2.5 air quality standard. The data in this section is based on information that has been pr ovided in other sections and appendices of this plan.



### 10. 1

. Reasonable Further Progress Requirements

The Clean Air Act (Act) requires attainment plans to meet RFP by achieving incremental

emission reductions to ensure attainment of National Ambient Air Quality Standards (NAAQS) by the attainment date (Section 171(1)). The Act does not identify specific emission reduction benchmarks that must be met for PM attainment plans.

EPA’s interpretation of the Act’s RFP requirement in the Implementation Rule fo r the PM 2.5 NAAQS identifies the concept of achieving generally linear progress (72 FR 20633). According to 40 CFR 51 Subpart Z, Section 51.1000 (Definitions):

The RFP benchmark plan is the RFP plan that shows generally linear progress from the

baseline emissions year through the milestone inventory years.

The baseline year inventory for RFP is the inventory for the year used as the base year for the attainment demonstration (for this plan, the baseline year inventory is 2002). Milestone year inventories occur in 2009 and 2012. Full implementation inventory is the level of emissions that demonstr ates attainment. In the Liberty

- Clairton nonattainment area the full implementation inventory is 201 4

.

Determination of RFP milestones involves several steps:

1. De termining the total reductions that must be achieved to reach attainment. The Plan satisfies this in Section 7, Modeling Procedures

. 2. Determine the attainment year that is as expeditious as practicable. This plan

identifies 201 4 as the most expeditious at tainment date practicable in the Liberty

Clairton nonattainment area. 3. Determining the fraction of reductions that are achieved in each milestone year.

The Implementation Rule recognizes that the attainment demonstration will identify the pollutants to be included in the RFP demonstration, the relative reductions needed for each of these pollutants, and the attainment year.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 62



### 10 .2

. Reasonable Further Progress Calculations

Tables 10

- 1, 10

- 2, and 10

- 3 show benchmark calculations specified in EPA’s Implemen tation

Rule.

Table 10

- 1 : Emissions Inventory Adjusted for Plan Control Strategy ( in Tons per Year )

Description 2002 2009 2012 201 4

Direct PM 2.5 Inventory After Plan Control Strategy 2,270.6 1

, 968.8 1

, 849.9 1

, 392.6

NO

x Inventory After Plan Control Strat egy 229,571.7 120,414.1 108,565.5 108,565.5

SO 2 Inventory After Plan Control Strategy 587,201.4 141,772.8 132,598.7 132,598.7

NOTES:

 D irect PM 2.5 inventor ies are based o n the Liberty

- Clairton area only . They include direct PM 2.5 emissions from point, ar ea, nonr o a d, and mobile sources

.

 NO

x and SO 2 precursor inventories include point sources that were modeled within the 150 km PM 2.5 modeling domain described in Section 7, but limited to Pennsylvania sources outside the Liberty

- Clairton

area in accordance w ith guidance provided in 72 FR 20636. Precursor inventories also include area, nonroad, and mobile sources within the Pittsburgh

- Beaver Valley area only.

 Regional control measures (CM) are already incorporated into the MANE

- VU regional inventories.

 2012 e missions for uncorrected sources are assumed to be representative through 201 4

. See Section 7.

Table 10

- 2 : Determining Benchmark Milestones as Tons per Year of Reductions

(Calculations described in footnotes)

Column

No. 2 3 4 5 6 7 8 9

Pollu tant 2002

Emissions Inventory 1 Attainment

Benchmark ( tons/year ) Number of

tons to be

reduced 3 Tons to be

reduced by

2009 (relative to 2002) 4 2009 EI

Benchmark ( tons/year ) 5 Tons to be

reduced by

2012 (relative to 2002) 6 2012 EI

Benchmark, ( tons/year ) 7 201 4 EI

Bench mark ( tons/year ) 8

Direct

PM 2.5 2,270.6 1,392.6 878.0 512.2 1,758.4 731.7 1,538.9 1,392.6

NO

x 229,571.7 108,565.5 121,006.2 70,586.9 158,984.8 100,838.5 128,733.2 108,565.5

SO 2 587,201.4 132,598.7 454,602.7 265,184.9 322,016.5 378,835.9 208,365.5 132,59 8.7

1 Column 2 shows the ba seline inventories from Appendices F and H (Local ACHD and MANE

VU Regional inventories )

2 Column 3 comes from Table 10

- 1, which shows that the 201 4 inventory with plan contr ols that will bring the Liberty

- Clairton area into at tai nment

. 3 Column 4 = Column 2

– Column 3

4 Column 5 = 7/1 2 of Column 4;

5 Column 6 = Column 2

– Column 5

6 Column 7 = 10/1 2 of Column 4;Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 63

7 Column 8 = Column 2

– Column 7

8 Column 9 = Column 3

Table 10

- 3 : Comparison of 2009 and 2012 RFP Benchmarks and P rojected Levels

Year Direct PM 2.5 NO

x SO 2 Benchmark 1 Projected

Level 2 Benchmark 1 Projected

Level 2 Benchmark 1 Projected

Level 2

2009 1,758.4 1,968.8 158,984.8 120,414.1 322,016.5 141,772.8

2012 1,538.9 1,849.9 128,733.2 108,565.5 208,365.5 132,598.7

1 From Table 10

- 2, Columns 6 and 8

2 From Table 10

- 1, shaded cells

As discussed earlier, EPA’s Implementation Rule specifies that generally linear progress should be achieved and that emissions in the milestone years should be at levels that are roughly

eq uivalent to the benchmark emission levels. The 2009 and 2012 projected levels shown in

Table 10

- 3 are the milestone year e mission levels for RFP. Table 10

- 4 presents calculations that demonstrate that the emission reductions achieved meet the RFP require ments. Cumulative emission reductions are the reductions achieved from the 2002 baseline emissions; they include the reductions in emissions of all three pollutants from the local control measures in the plan, as

well as reductions in NO

x and SO 2 emission s from regional control programs. Note: PM 2.5 reductions from the shutdown of Batteries 7

- 9 began in April 2009

. The RFP reductions used for

20 09 PM 2.5 values were estimated as 71 % of the total eventual r eductions achieved by 2012.

Table 10

- 4 : Fractio n of Reductions Achieved in Each Milestone Year

Milestone

Year Emissions

( tons/year ) Cumulative

Emission

Reductions ( tons/year ) Percent of Emission

Reductions Needed

for Attainment Percent

Per Y ear

PM 2.5 2002 2,270.6

- - - 2009 1,968.8 301.8 34 1.9

20 12 1,849.9 420.7 48 1.9

2014 1,392.6 878.0 100 3.2

NO

x 2002 229,571.7

- - - 2009 120,414.1 109,157.6 90 7

2012 108,565.5 121,006.2 100 5

2014 108,565.5 121,006.2 100 4

SO 2 2002 587,201.4

- - - 2009 141,772.8 445,428.6 98 11

2012 132,598.7 454,602 .7 100 8

2014 132,598.7 454,602.7 100 6Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 64

As shown in the T able 10

- 4 , the PM 2.5 p lan meets RFP requirements, with continuous and generally steady progress towards attainment by achieving between 1.9 % to 3.2 % emissions

reductions per year of direct PM 2.5

. Emissions from NO

x and SO 2 in both milestone years are below the attainment level. In terms of cumulative progress towards attainment, there is steady progress for NO

x and SO 2 pollutant as shown in Table 10

- 4, so that 100% of the necessary

reductions are achieved by the attainment date.

With respect to direct PM 2.5 , reductions will be achieved in the Liberty

- Clairton by the end of

2009 and 2012 , ensuring continuous progress towards attainment in year 2014 . Attainment requires a sizable magnitude of redu ctions from the Liberty

- Clairton area’s major stationary

source

.

Due to the significant nature of the new measures anticipated to be put into effect by the area’s major industrial source and the technical complexities of implementation, the final incremen t of the emission reductions needed for attainment, will not occur until the end of 2013

.

In summary:

Reductions in direct PM 2.5 and precursor emissions are being achieved as quickly as possible;

There is a downward trend in emissions of direct PM 2.5 bet ween 2009 and 201 4 at a rate
of 1.9 % to 3.2 % per year; The Liberty

- Clairton area will reach attainment as expeditiously as practicable.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 65



## 11. Contingency Measures

According to the Federal Register , V ol. 72, N o. 79

, P age s 20642

- 3, PM 2.5 contingency m easures are additional control measures to be implemented in the event that an area fails to meet RFP or fails to attain the standards by its attainment date.

The Liberty

- Clairton area was designated nonattainment in 2005. This attainment demonstration

is based on a n attainment date of 2015. Contingency measures are recommended to be based on approximately one year of additional emissions reduction. The emissions reductions anticipated by the contingency measures should be equal to approximately 1 year ’s worth of emissions reductions necessary to achieve RFP for the area.

Table 11

- 1: Calculation of Required and Excess Emission Reductions

Liberty

- Clairton Area PM 2.5 (tons/year)

Base line ( 2002) Liberty

- Clairton Area

Emissions 2270.6

Projected (2014) Liberty

- Clairton Area

Emissions 1392.6

Change in E missions 878.0

Target R eductions for C ontingency Measures (1/10 ) 87.8



### 11.1. Indentified Contingency Measures to be Implemented

The Federal Register , V ol. 72, N o. 79, P age s 20642

- 3 says that contingen cy measures should consist of other control measures for the area that are not included in the control strategy fo r the

SIP. This could include f ederal measures and local measures alread y scheduled for implementation, along with measures to be implemented if attainment is not achieved.

Should reasonable further progress (RFP) not be met by 2009 or 2012, or should attainment not be achieved by 2015, t he consent order and agreement with U. S. Steel ( as amended in September 2010 ) specifies the following: w it hin 30 months after receiving notice from ACHD that EPA is requiring implementation of the contingency measures, U. S. Steel ’s Clairton Plant will cease operation of the current Quench Tower 1 as the primary quench tower for Batteries 1

- 3 or implement emi ssion reductions greater than or equal to 90 tons per year (unless a lesser

amount is needed to demonstrate attainment of the annual PM 2.5 NAAQS). The use of a lowLiberty

- Clairton PM 2.5 SIP Revision April 2011 Page 66

emission quench tower in place of the current Quench Tower 1 would lead to a reduction of 1 73 tons per year of primary PM 2.5 , as given in Table 11

- 2.

Additionally, the consent order and agreement included c oke oven wall rebuilds for Battery 20 to be implemented in late 2014. E mission s reduced by the improvem ents to Battery 20 are expected to b e 9 tons/year

. Total emissions reductions from the contingency measures are given

in Table 11

- 2.

Table 11

- 2: Contingency Measures Emission Reductions

Process PM 2.5 2014

Inventory

Value ( tons/year ) PM 2.5

Contingency

Value ( tons/year ) PM 2.5 Reduction

( In ventory

– Contingency )

Value ( tons/year )

New Low Emission Tower

for Batteries 1

- 3 27 4.8 10 2 .5 17 2.3

Battery 20

– Rebuilds,

Combustion Stack 17 .5 9 .4 8 .1

Battery 20

– Rebuilds,

Door Leaks 2 .4 1 .3 1 .1

T otal 294 .7 11 3.2 181.5

The Federal Register state s that emissions reductions anticipated by the contingency measures should be equal to approximately 1 year’s worth of emissions reductions necessary to achieve

RFP for the area. T he emission reductions given in Table 11

- 2 satisfy the require ment for

cont ingency measures.

Due to the shutdown of Batteries 7

- 9 at the U. S. Steel Clairton Plant in April 2009, reductions required for RFP in 2009 have already been achieved. RFP for 2012 is also projected to be

achieved due to the shutdown of Batteries 7

- 9, pe nding future calculation of 2012 emissions

inventories.



### 11.2. Contingency Measures

– SO 2 

### and NO

x

The Pittsburgh

- Beaver PM 2.5 non attainment area is a separate nonattainment area; however

, it completely encircles the Liberty

- Clairton nonattainment area. A s discussed in Chapter 3 of this SIP, i t has been shown that the Liberty

- Clairton area PM 2.5 due to long

- range transport and due

to SO 2 and NO

x conversion to nitrates and sulfates are consistent across both regions. The control strategy for these pollutan ts are discussed and presented in the Pittsburgh

- Beaver PM 2.5 SIP. Contingency measures for these pollutants are similarly presented within that SIP.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 67

The Liberty

- Clairton PM 2.5 non attainment area is located entirely within the borders of the Pittsburgh

- B eaver PM 2.5 non attainment area. The Liberty

- Clairton area is so small that sulfur dioxide and nitrogen dioxide do not have time to convert to sulfates and nitrates. There is very

little difference in sulfates and no difference in nitrates measured at Lib erty from the monitors in the larger non attainment area. The Pittsburgh

- Beaver SIP demonstrates that a modeled excess of

SO 2 and NO

x emissions provide for the required contingency measures.



### 11.3. Additional Contingency Measures

There are a number of co ntrol measures or voluntary emission reductions either are already implemented or on schedule to be implemented in the near future. EPA guidance encourages early implementation of contingency measures to guard against failure either to meet a

milestone or attain the standard. EPA's guidance on early implementation of control measures

encourages the early implementation of required control measures and of contingency measures as a means of guarding against failures to meet a milestone or to attain.

On Oct ober 9, 2008, Governor Rendell signed Senate Bill 295, which became Act 124 of 2008,

the Diesel

- Powered Commercial Motor Vehicle Idling Act (Act 124). Act 124 went into effect on February 6, 2009. PA DEP estimates that 50 percent of all long duration idl ing for Class 8 trucks will be eliminated in 2010 when the temperature exemption for sleeper truck rest expires. Statewide emission reductions are estimated to be 1610 tons, 45 tons

, and 30 tons per year for

NO

x , VOC, and PM 2.5 , respectively. PA DEP and ACHD may also utilize enhanced enforcement

to obtain additional emission reductions.

State

- wide regulations are in development and are anticipated to be adopted in the relatively near

future for NO

x controls for cement kilns, NO

x controls for glass furnac es, and PM controls for

outdoor wood furnaces.

Regulations to reduce VOC emissions are in development, including controls on the manufacture and use of adhesives, primers

, and sealants and regulations incorporating the Control Techniques

Guidelines issued by the EPA in 2006, 2007

, and 2008.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 68



## 12. Transportation Conformity

Section 176 of the CAA provides a mechanism by which federally funded or approved highway and transit plans, programs, and projects are determined not to produce new air quality

violatio ns, worsen existing violations, or delay timely attainment of the NAAQS. EPA regulations issued to implement transportation conformity provide that motor vehicle emission “budgets” establish caps of these emissions that cannot be exceeded by the predicted transportation system emissions in the future. Transportation agencies in Pennsylvania are responsible for making timely transportation conformity determinations. The responsible agency

in the Pittsburgh Area is the Southwestern Pennsylvania Commission, the designated Metropolitan Planning Organization (MPO) under federal transportation planning requirements.

Pennsylvania proposes to establish budgets for highway emissions for direct PM 2.5 and NO

x in order to ensure that transportation emissions do not impede clean air goals in the next decade and beyond for the Pittsburgh

- Beaver Valley nonattainment area, as well as for the Liberty

- Clairton

nonattainment area. The information in Table III

- 5, once the EPA approves it for purposes of conformity, will est ablish transportation conformity budgets for the Liberty

- Clairton a rea

.

Amendments to the 40 CFR part 93 transportation conformity regulations to address the 1997

PM 2.5 standard were published in the Federal Register on May 6, 2005 (70 FR 24280) to accoun t
for PM 2.5 and its precursors. Section 93.102 requires conformity determinations to be applicable

to direct emissions of PM 2.5 and NO

x (unless a determination is made that transportation

- related emissions are not significant contributors to PM 2.5 ), but t o emissions of SO

x , VOC, and NH 3 only if a finding is made that transportation

- related emissions of these pollutants are significant

contributors to PM 2.5

.

M otor vehicle emissions budget for SOx, VOC, and NH 3 are needed only if the state air agency

direct or or the EPA Regional Administrator makes a finding that motor vehicle emissions budgets must be established in order to attain the NAAQS for PM 2.5 . Because the reactions that form particulate matter from emissions of VOC are complex and highly variable, there is considerable uncertainty regarding the contribution of VOC to particulate formation.

Likewise, much uncertainty remains regarding the role of NH 3 in particulate formation. T he Commonwealth of Pennsylvania is not considering VOC or NH 3 as PM 2.5 precursors for the purpose of the attainment plan for the Pittsburgh

- Beaver Valley nonattainment area, because of the uncertainty surrounding their role in particulate formation. Therefore, this SIP revision is not establishing a motor vehicle emission bu dget for VOC or NH 3

.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 69

T able s 12

- 1 and 12

- 2 below show the annual and daily motor vehicle emission budgets compiled by the Southwestern Pennsylvania Commission (SPC) for the Liberty

- Clairton a rea conformity

determination over the period 2009

- 2012. 8 Budge ts for PM 2.5 and NO

x show decreases over the future timeframe on annual and daily bases.

Table 12

- 1: Annual Motor Vehicle Emission Budgets ( T ons /Y ear)

Year PM 2.5 NO

x 2009 1.5 72.7

2011 1.4 58.9

2012 1.3 52.4

Table 12

- 2 : Daily Motor Vehicle Emissi on Budgets (T ons/ D ay )

Year PM 2.5 NO

x 2009 0.004 0.180

2011 0.004 0.146

2012 0.004 0.129

T able s 12

- 1 and 12

- 2 do not include road dust emissions from paved and unpaved roads, or

construction

- related fugitive dust emissions in the area source inventory , due to the extremely small area that Liberty

- Clairton e ncompasses

.

8 Taken from Air Quality Conformity Determination, Pittsburgh Transporta tion Management Area , SPC, January

2009.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 70

Figure s 12

- 1 and 12

- 2 below show the predicted long

- term estimates for annual and daily PM 2.5 from the SPC conformity assessment

.

Figure 12

- 1 : Conformity Assessment for the Liberty

- Clairton Area, Annual PM 2.5

Figure 12

- 2 : Conformity Assessment for the Liberty

- Clairton Area, Daily PM 2.5Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 71



## 13. Weight of Evidence

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

will achiev e attainment in the allotted time.



### 13.1

. Local and Regional Tr ends

Within the five municipalities that make up the nonattainment area (Clairton, Glassport, Lincoln, Port Vue, and Liberty,) there are two PM 2.5 monitors, along with six other monitors that gauge
PM 2.5 throughout Allegheny County. Figure 13.1 compares the PM 2.5 annual averages of each monitor throughout Allegheny County

.

Figure 13

- 1: PM 2.5 FRM Annual Averages in Allegheny County, 2000

- 200 9

Since 2005, all sites but Liberty and North Braddock had annual averages below the EPA

standard

. In 2009

, all monitor s recorded an annual average equal to or below the standard.
[Note: Moon and North P ark sites did not operate in 2008 and were restarted in 2009.] TheLiberty

- Clairton PM 2.5 SIP Revision April 2011 Page 72

Design Values (3

- year averag es) for PM 2.5 show a more consistent and level trend toward lower concentrations, as seen in Figure 13.2

.

Figure 13

- 2: PM 2.5 FRM 3

- Year Average s in Allegheny County, 2000

- 2009

While Liberty remains a clear outlier in comparison to other Allegheny C ounty sites

, concentrations have been dec reasing consistently since the 20 0 5

- 20 0 7 average.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 73 Figure 13

- 3: Liberty and Clairton Annual Design Values with Trend L ines

Based on monitored data alone, t he linear regression trend lines in Figure 13. 3 s how declining design v alues of PM 2.5 through 2014. These trend lines do not account for any additional influences to future emission levels that are discussed in this SIP, such as the shutdown of

batte ries at the U. S. Steel Clairton Plant or diesel parti culate

- reducing projects in Allegheny County

. T hough not statistically significan t 9

, both sites show a marked long

- term decline in

PM 2.5 concentrations

.

Because of regional transport of particulates, emissions from upwind states also contribute to

locali zed exceeda nces. Reductions in regional emissions like those shown in the Reasonable Further Progress section of this SIP will help lower the regional portion of PM 2.5 at Liberty and

Clairton.

9 Based on EPA Region III’s R Analysis of Pittsburgh

- Beaver Valley and Liberty Clairton PM 2.5 Areas, October

2009Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 74



### 13.2

. Wood Stoves & Wood

- Fired Boilers

Wood burning stove s and outdoor hydronic wood boilers are on the rise in Allegheny County, which currently does not have any regulations concerning particulate emission controls on stove

and boilers. Visible emission and odor regulations are in place which can manage wood burning stoves and boilers, but there is currently no regulation concerning the efficiency of models.

EPA

- certified wood stoves can reduce particulate emissions 70

- 80% per unit. EPA

- certified boilers, which bu rn cleaner than non

- certified boilers , also reduce emissions. Many states, regions, and municipalities have begun looking into wood

- stove and wood

- boiler regulations to cut down on particulate pollution. Pennsylvania finalized its wood boiler rule on October 2, 2010, requiring the use of EPA

- certi fied Phase 2 boil ers in the state of Pennsylvania

. A CHD has participated in EPA’s Wood Stove Changeout Campaign, replacing 17 6 older woodstoves in Southwest Pennsylvania with newer, cleaner units. According to EPA 10 , changing out 20 wood

stoves results in a net reduction of 1 ton of particulate pollution. An awareness campaign to inform municipalities of pollution from wood stoves and boilers is underway by ACHD.

Receptor modeling showed that v egetative burning is a contributor of PM 2.5 at Liberty. The

source a pportionment r esults using the Posit ive Matrix Factorization Model ( PMF Ve rsion 1.1)

can be found in Appendix E

.

Further work in this area, including local regulations against wood

- burning stoves and boilers, will reduce particulate pollution fur ther in the nonattainment zones.



### 13.3

. National Regulations

– CAIR and TR

The 2005 Clean Air Interstate Rule (CAIR) was used in the MANE

- VU regional modeling and projected that each participating state w ould have a 60% reduction of NO

x (based on 2003

le vels) and a 70% reduction of SO 2 over the course of 10 years. EPA list ed Allegheny County as

one of the nonattainment regions for particulates that w ould receive the greatest benefit in particulate reduction from CAIR. Surrounding states that contribute to regional trends, such as Ohio and West Virginia, were also covered by CAIR, which w ould help reduce regional particulate pollution that may be from a source outside Allegheny County.

CAIR was remanded to EPA in December, 2008

. EPA has proposed the Tr ansport Rule (TR) a s a replacement rule to CAIR, to be effective in 2011. The Transport Rule is expected to b e as stri ct as or stricter than CAIR. For a quantitative analysis, SO 2 and NO

x emissions from the

2012 CAIR inventory ( used in the regional model ing for this SIP) were compared to emissions

used for the proposed Transport Rule 2014 control case (as of October 2010). Emission totals for power plants (EGUs) in the 150 km modeling domain used for this SIP are given in Table

13.1

.

10 http://www.epa.gov/burnwise/index.htmlLiberty

- Clairton PM 2.5 SIP Revision April 2011 Page 75 Table 13

- 1 : Futu re Case CAIR and TR Emissions

Plant Name SO2 CAIR 2012 (tons) SO2 TR

2014 (tons) NOx CAIR

2012 (tons) NOx TR

2014 (tons)

Cardinal 14045 14006 3668 2484

R E Burger 4062 5761 3078 3712

W H Sammis 24541 21550 8466 7750

Beaver Valley 3750 1626 4544 229 0

Armstrong 13313 2822 2627 3779

Bruce Mansfield 18000 23101 4396 5455

Cheswick 4876 4527 1170 1246

Elrama 4595 4059 5847 6647

Hatfield's Ferry 23194 14507 6487 15412

Homer City 9925 12182 4032 3936

Keystone 10363 13055 2713 2603

Mitchell (PA) 1527 649 3204 2844

New Castle 15062 8988 3555 2888

Fort Martin 49567 7135 10858 7755

Kammer 28490 5188 14245 1353

Mitchell (WV) 15467 19956 3867 3368

TOTAL 240778 159112 82756 73522

DIFFERENCE (CAIR minus TR) 81666 9234

Emissions in Table 13.1 show th at the 2012 CAIR case included 90900 more tons of SO 2 and

NO

x emissions than those in the proposed TR 2014 case. This indicates that modeled emissions

from the tri

- state EGUs were a conservative estimate of future modeled impacts.

For a qualitative anal ysis, committed SO 2 and NO

x control schedules used for the Transport Rule and progress updates for the tri

- state EGUs are shown in Table 13.2.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 76 Table 13

- 2 : EGU Control Implementation Schedule and Progress

Plant Name Committed SO2

TR Controls C ommitted NOx

TR Controls Progress (as of February 2011)

Cardinal FGD by 2010

- 2012 SCR before 2009 FGD installed on Units 1

- 2, Unit 3 underway

R E Burger FGD by 2010

- 2011 SNCR before 2009 Units 4

- 5 shutdown in Dec. 2010 (no conversion to biomass)

W H Sam mis FGD by 2010

- 2011 SCR by 2012 FGD and SCR completed in Dec. 2010

Beaver Valley

--- SNCR before 2009 N/A

Armstrong

--- SNCR before 2009 N/A

Bruce Mansfield

--- SCR before 2009 N/A

Cheswick FGD by 2010

- 2011 SCR before 2009 FGD completed in 2009

Elram a

--- SNCR before 2009 N/A

Hatfield's Ferry FGD by 2009 SNCR before 2009 FGD completed in Oct. 2009

Homer City FGD by 2012 SCR before 2009 Unknown

Keystone FGD by 2009 SCR before 2009 FGD completed in 2009

Mitchell (PA)

--- --- N/A

New Castle

--- SNCR before 2009 N/A

Fort Martin FGD by 2012 SNCR before 2009 FGD completed in Feb. 2010

Kammer

--- SCR by 2012 Unknown

Mitchell (WV)

--- SCR before 2009 N/A

Table 13.2 shows that the committed dates fall before the attainment year of 2014 used in this

S IP and that most controls have been implemented ahead of schedule. Progress for Homer City

and Kammer control s are unknown at the time of this SIP. Additionally, R E Burger has agr eed

to shut down its Units 4

- 5, in place of the proposed conversion to bio mass.



### 13.4

. Diesel Campaign

In addition to other strategies, ACHD has also been working to encourage diesel fuel engine retrofits on local school buses and municipal vehicles. The approximately 2,000 school buses in Allegheny County emit a total of abo ut 12 tons of particulate matter, in addition to 370 tons of hydrocarbons.

Allegheny County offers 100% reimbursement grants for school bus retrofits to districts at which at least 40% of the students are eligible for free or reduced

- cost lunches (based on income) and

75% reimbursement for all other districts

. The utilization of diesel retrofits will allow the participating municipalities to reduce toxic diesel emissions 30

- 90%, depending on the type of

retrofit chosen.

Currently a contractor that serve s the Pittsburgh Public Schools has requested $ 450 ,000 for 37

school bus retrofits. In addition, t he scho ol districts within the Liberty

- Clairton nonattainmentLiberty

- Clairton PM 2.5 SIP Revision April 2011 Page 77

area are all eligible for the program, and the five townships that make up the area are current ly working on a diesel retrofit project along with ACHD and the Allegheny County Partnership to

Reduce Diesel Pollution.

The project will provide diesel retrofits to municipal vehicles in these townships and is currently underway. A Clean Air Fund grant of $200,000 has been allocated for the purpose of the project, and ACHD and the Diesel Partnership are working with the local governments to install retrofits on municipal vehicles.

Anti

- idling regulations for school buses have been in effect since late 2 004 in Allegheny County. School buses are not allowed to idle for longer than 5 minutes, unless actively picking up or discharging students. The regulation also restricts idling near school air intakes. Lowered idling

times of buses reduces diesel consum ption and diesel emissions.

A nti

- idling regulations for trucks and transit buses have been in effect since 2005. Drivers of diesel engine vehicles can be reported to ACHD and can be fined up to $500 if they are found to idle unnecessarily for more than 5 minutes in a one

- hour period.

In addition, Pennsylvania recently adopted a state

- wide ban on unnecessary diesel idling. Outreach and public education for these new regulations are currently underway.

Emission reductions due to school bus and municipal vehicle retrofits and the anti

- idling regulations are not factored into the modeled data of this SIP, and represent additional reduction strategies that are ongoing within Allegheny County and the Liberty

- Clairton nonattainment

area.



### 13. 5

. State and C ompetitive ARRA Clean Diesel Grants

The Allegheny County Health Department

, with input from Group Against Smog and Pollution (GASP) and Clean Water Action

, applied for and was awarded federal funds for projects to reduce diesel particulate pollution in th e spring of 2009. A total of $3,498,106 will be distributed among five partners in a project that is scheduled during the 2009

- 2010 timeframe

. The projects will help reduce diesel pollution in Pittsburgh, the Liberty

- Clairton nonattainment area, and thro ughout Southwestern PA. The money comes from the American Recovery and Reinvestment Act (ARRA) and the National Clean Diesel Program. These projects will take place over the following year, and will be completed by September 2011

.

The Port Authority of Allegheny County will use ARRA funds to assist in replacing two 1996

- model transit buses with 2010

- model cleaner diesel hybrid electric buses and to repower nine

2003

- model diesel buses with engines that meet the new, higher 2007 emission standards. This will reduce particulate matter pollution by approximately 0.1 tons per year, carbon monoxide by 2.8 tons per year, and nitrogen oxides by 6.8 tons per year.

Constructors Association of Western Pennsylvania will use ARRA funds for retrofit technologies

– e ngine repowers, upgrades and diesel particulate filters

– to upgrade 42 diesel

- powered, heavyLiberty

- Clairton PM 2.5 SIP Revision April 2011 Page 78

non

- road construction equipment in Western Pennsylvania. The various upgrades will reduce particulate matter pollution by 1.8 tons per year, carbon monoxide by 1 4.6 tons per year, hydrocarbons by 2.09 tons per year, and nitrogen oxides by 9.73 tons per year.

Harsco Metals North America provide s trucking for U. S. Steel. With ARRA funds they will install diesel particulate filters on 11 dump trucks operating in and around U. S. Steel's Mon Valley Works. Once upgraded, these dump trucks will be 90

- percent less polluting than they are today. It is estimated that these diesel particulate filters will remove 0. 06 tons of particulate matter per year, 0. 20 tons of c arbon monoxide per year, and 0.91 tons of hydrocarbons per year.

With ARRA funds CSX Transportation will replace one vintage diesel switcher locomotive

without emission controls with a two

- engine configuration that has the latest in emission control

tech nology. The GenSet switcher locomotive engine will operate at CSX's McKeesport/Demmler rail yard, bringing immediate air quality benefits to the residential neighborhood nearby. The project will cut diesel particulate matter by approximately 0.5 tons

per year, carbon dioxide by 172 tons per year, and nitrogen oxides by 16.6 tons per year. It will also save 15,000 gallons of diesel fuel annually and provide quieter operation for the nearby residents of McKeesport.

The Allegheny County Health Department w ill also r eceive $433,100 to equip diesel

- powered municipal waste haulers with diesel particulate filters

. The money comes from the ARRA via

the State Allocation Grant Program. A previous project led by GASP and Clean Water Action installed diesel partic ulate filters on 13 waste haulers in the city, reducing diesel particulate pollution from each vehicle. This new funding will help ACHD, GASP, and Clean Water Action complete the project by retrofitting 33 of the remaining city vehicles.

Because of the f

requent starting and stopping of the vehicles, and the proximity to all neighborhoods and families in the city, this project will significantly help local air quality. The project will take place from July 2009 through August 2010, by when all vehicles ar e scheduled

to be retrofitted.

These projects are additional PM 2.5 reduction strategies outside of the modeled data within this

SIP.



### 13.6

. Population Trends

Allegheny County is unique in the fact that the population has been declining since the 1960 s. Localized regions of population growth are occurring, but the general trend for the county is one of negative growth. According to a University of Pittsburgh study of housing and socio

demographic trends in Allegheny County 11 , four of the five nonattain ment municipalities have been in decline for nearly 50 years. In the 1990

- 2000 period, Clairton has experienced a change

of

- 12.1%. Glassport had a decline of

- 10.6%, Port Vue of

- 8.9%, and Liberty of

- 2.7%. Lincoln

11 "Al legheny County Housing and Socio

- Demographic Trends," co

- author with Christopher Briem and Angela Williams Foster. Prepared for the Allgheny Couny Comprehensive Plan, University Center for Social and Urban Research, University of Pittsburgh
and McCormick T aylor, Inc., Pittsburgh, December 2005.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 79

experienced an increase in population o f 1.3%, though this is only from a gain of 15 people within the 10 year period.

Lowering populations signal lower use of cars and a lower need for school buses and other diesel engine driven vehicles. Additionally, various consumption activities will de cline (power use, water use, et cetera,) and lower amounts of waste will be produced. Combining all of this with the local regulations such as the school bus idling regulation, and national regulations and trends

toward more efficient and clean cars and f uels, it is assumed that particulate emissions in the

nonattainment areas will reach low er levels than the models show.

Figure 13

- 4 : Population Trends for Allegheny County, 1990

- 2000 { Deitrick, et al., 2005 }Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 80



### 13.7

. Monitored Data During Low Production

Economic recession i n 2009 led to decreased levels of production at many industrial facilities in Southwest PA. To examine the effect of low production levels on PM 2.5 concentrations, 2009

continuous PM 2.5 (TEOM) and Federal Reference Method (FRM) data w ere compared to previ ously monitored data for previous years . Similar to speciation data comparisons, TEOM

and FRM data from Liberty is compared to that from Lawrenceville to reveal differences between the regio nal and localized components. [ Note: TEOM monitors are not consi dered

“official” PM 2.5 monitors by EPA but can be used for short

- term trends and f or real

- time reporting of data. D ata shown here has not b een corrected to make FRM

- like.]

Long

- term hourly averages for the c ontinuous TEOMs are shown in Figure 13

- 5 for Li berty and Lawrenceville during the period of 2000

- 2008. Hours are given according to Eastern Standard Time (EST).

Figure 13

- 5 : Long

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

- 2008

Long

- terms trends show that Liberty TEOM co ncentrations are much higher than Lawrenceville during nighttime hours but are nearly similar during daytime hours (specifically during afternoon to early evening hours). This diurnal trend is due to the strong influence of inversions that lead to the nig httime accumulation of particles in the Liberty

- Clairton area. Smaller peaks can be seen at Lawrenceville due during peak traffic periods, also possibly influenced by inversions.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 81

Long

- term hourly averages at each site were compared to averages for 2009 d ata . The Liberty long

- term averages are shown along with 2009 averag es in Figure 13

- 6 below.

Figure 13

- 6 : Hourly 2009 PM 2.5 TEOM Averages at Liberty Compared to Long

- Term 200 0

- 2008 Averages

Liberty TEOM data show the same diurnal trend in 2009 as in previous years but at lower concentrations. Additionally, the dotted high

- low lines visually indicate a higher nighttime

difference between long

- term and 2009 data

.

Figure 13

- 6 is similar to the before

- and

- after modeled hourly concentrations graph sho wn in the

model demonstration discussion (Figure 8

- 5) in this SIP. This is evidence that controls used in the modeling demonstration should show actual results similar to the 2009 low

- production

scenarios.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 82

The Lawrenceville long

- term averages are shown along with 2009 averages in Figure 13

- 7

below

.

Figure 13

- 7 : Hourly 2009 PM 2.5 TEOM Averages at Lawrenceville Compared to Long

- Term

200 0

- 2008 Averages

Lawrenceville TEOM data show an overall decrease in concentrations in 2009 , with the high

- low

line s showing a slightly higher difference between long

- term and 2009 daytime concentrations.

Decreases in overall concentrations at both sites can be due to regionally lower production levels, while lower nighttime levels at Liberty may be evident of lower l ocal source production levels. To examine this, differences in concentrations between the two sites were calculated.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 83

T able 13

- 1 below shows quarterly average FRM data over a 5

- year timeframe for years 2 005

- 2008 and for 2009 . Averages are given for Libe rty, Lawrenceville, and the difference between the two sites (Liberty minus Lawrenceville).

Table 13

- 3 : PM 2.5 FRM Quarterly Averages, 200 5

- 2008 and 2009

Liberty 1Q 2Q 3Q 4Q

2005

- 2008 Average 14.9 19.1 23.6 18.9

2009 15.0 13.7 15.1 16.4

Lawre nc e ville 1Q 2Q 3Q 4Q

2005

- 2008 Average 12.5 13.8 19.4 12.3

2009 12.7 11.2 12.9 9.7

Difference (Lib.

- Law.) 1Q 2Q 3Q 4Q

2005

- 2008 Average 2.4 5.2 4.2 6.6

2009 2.3 2.5 2.2 6.7

The difference parameters for 2 nd and 3 rd quarters in 2009 are signif icantly smaller than in previous years, coinciding with low production levels at local source s

.

At the U. S. Clairton Plant, Batteries 13

- 15 were idled from Mar

. - Dec. 2009, along with B Battery from Apr.

- Jun. 2009 , due to recession

. Batteries 7

- 9 were al so permanently idled in

A pril 2009. At t he RRI Energy Elrama power plant

, all boiler units operated at an average capacity of 8.1% from March to October 2009.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 84

To further illustrate the lower localized source influence in 2009 data, a plot of the Libert y

Lawrencev ille TEOM difference is shown in F igure 13

- 8 for 2009 and previous years. For this chart, hourly averages for 200 0

- 2008 are compared to hourly averages for 2009 . The hours have been shifted by 12 hours to show the nighttime period in the cente r of the chart

.

Figure 13

- 8 : Hourly 2009 PM 2.5 TEOM Average Differences B etween Liberty an d

Lawrenceville Compared to Long

- Term 200 0

- 2008 Data

The nighttime peak in the Liberty

- Lawrenceville difference has been lowered in the 2009 data, reflecting the influence of reduced production in 2009 compared to t hat of normal production in

2000

- 2008. Decreases in concentration differences are greatest in the late evening/early morning period.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 85



## 14

. Emergency Episodes

Subpart H of 40 CFR part 51 specifies requirements for SIPs to address emergency air pollution episodes in order to prevent air pollutant levels from reaching levels determined to cause significant harm to the health of persons. No levels are currently recommended by EPA for PM 2.5
emergency e pisodes, however ACHD Rules and Regulations Article XXI §2106.03, which defines the procedures for emergency air pollution episodes as well as the values for air pollutants, includes PM 10 levels. ACHD will use the levels set for PM 10 as PM 2.5 levels.

ACH D assumes one μ g/m 3 of PM 2.5 to be equal to at least one μ g/m 3 o f PM 10 , therefore if any

PM 2.5 monitor exceeds any of the levels listed for PM 10 , it will be assumed that the PM 10 levels have been exceeded, and appropriate action will be taken according to the predetermi ned Episode Actions of Article XXI §2106.04.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 86



## 15. Legal Documents

1 5

. 1. Notice of Public Hearing and Comment PeriodLiberty

- Clairton PM 2.5 SIP Revision April 2011 Page 87



### 1 5

. 2. Transmittals of Hearing Notice to PA DEP and EPALiberty

- Clairton PM 2.5 SIP Revision April 2011 Page 88Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 89Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 90



### 1 5

. 3. Proof of Publication and Certification of Public Hea ringLiberty

- Clairton PM 2.5 SIP Revision April 2011 Page 91 Revision 6 7

SIP Revision for PM 2.5 for Liberty

- Clairton

Certification of Hearing

Jason Maranche deposes and says that he is an Air Pollution Control Engineer with the Air Quality Program of the Allegheny County Health Department and hereby c ertifies that a Public Hearing was held on December 16, 2010 regarding the proposed revision to Allegheny County's portion of the State Implementation Plan (SIP) for particulate matter 2.5 micr ons or less in diameter (PM2.5) ; that the opportunity for writ ten comments was given during the period November 15, 2010 through December 16, 2010 in accordance with the requirements of 40 CFR 51.102; that notice of such hearing was given by publication in a newspaper of general

circulation on November 12, 2010 ; an d to the best of his knowledge, belief and understanding, such proceedings were in full compliance with all applicable s tate and f ederal laws, regulations, and other requirements.

Jason Maranche Air Pollution Control Engineer III Air Quality Program Allegheny County Health Department

December 17, 2010

DateLiberty

- Clairton PM 2.5 SIP Revision April 2011 Page 92



### 1 5

. 4

. Summary of Public Comm ents and Responses

Comment and Response Document for the Proposed SIP Revision 6 7

Revision to State Im plementation Plan for PM 2.5 for Allegheny County

Liberty

- Clairton PM 2.5 Attainment Plan

December 16, 2010 Public Hearing Public Comment Period ending December 16, 2010

PROBLEM STATMENT Comments related to the description of the Liberty

- Clairton PM 2.5 problem.

1. Comment: T

he Lawrenceville monitor was used to evaluate and compare regional

concentrations of PM 2.5 . ACHD has not adequately explained how it came to this conclusion and how this monitor can be used to evaluate regional concentrations of PM 2.5 . The Lawrenceville monitor does not represent background PM 2.5 concentrations of Allegheny County or the Pittsburgh

- Beaver Valley area nor is it representative of conditions in the Liberty

- Clairton area.

Commenter : Coleen M. Davis, Senior Environmenta l Engineer, U. S. Steel Corporation.

Response : The Lawrenceville site has been used as the urban site for the Pittsburgh

- Beaver Valley area. Speciation sites within the Pittsburgh

- Valley area (excluding Liberty) have been

shown to measure consistent con centrations for major species. The background site used for Pittsburgh

- Beaver Valley in EPA’s designation process was Dolly Sods, WV, a rural monitor located in a U.S. Wilderness area with lower concentrations than any of the Pittsburgh

Beaver Valley spec iation sites. For comparison of regional and localized components of

PM 2.5 , the Lawrenceville site was therefore used as the regional site along with Liberty as the local site for the Liberty

- Clairton area.

2. Comment: ACHD should update its PM 2.5 SIP doc ument to include the most recent design values. This should also include updating various figures within the SIP document to include the most recently available PM 2.5 concentrations.

Commenter : Diana Esher, Director, Air Protection Division, U.S. EPA Re gion III.

Response : The SIP has been updated with PM 2.5 design values through 2009.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 93

CONTROL STRATEGY Comments related to the controls used to show projected attainment.

3. Comment: U. S. Steel has concerns over the Department's reliance on emission

red uctions as a result of CAIR as a part of the strategy. If CAIR or other regional reductions are not met as outlined in the plan, U. S. Steel would be forced to implement contingency measures for which the Department has failed to show how they would enabl e the area to

reach attainment.

Commenter : Coleen M. Davis, Senior Environmental Engineer, U. S. Steel Corporation.

Response : Reductions projected by the Clean Air Interstate Rule (CAIR) represent the best

data available for future PM 2.5 levels, specif ically for sulfates and nitrates. Future projections, though not available at this time, are expected to be equal to or better than the CAIR reductions. The Pennsylvania CAIR regulation was made final in December 2009, and will be in place prior to the S IP attainment date.

4. Comment: EPA's Clean Air Interstate Rule (CAIR) is listed as one of the control measures used to demonstrate attainment of the 1997 Fine Particulate Matter (PM 2.5 ) National Ambient Air Quality Standards (NAAQS). However, CAIR cannot be used to

demonstrate attainment of the 1997 PM 2.5 NAAQS if an area is requesting an extension of the attainment date beyond April 5, 2010.

Commenter : Diana Esher, Director, Air Protection Division, U.S. EPA Region III.

Response : The Liberty

- Clairton Area cannot reach attainment without precursor emission controls at local and distant power plants. The Transport Rule (TR) has been proposed as a replacement for CAIR; and controls in the final Transport Rule (to be effective in 2011) will

be similar to those with CAIR. SO 2 and NO

x emissions used in the proposed Transport Rule (as of October 2010) for power plants in the tri

- state area were found to be 90900 tons less than emissions modeled. Therefore, the modeled emissions using CAIR controls may be

c onsidered a conservative projection of future case emissions. A comparison of CAIR and TR emissions and controls has been added to the weight of evidence section of the SIP.

EMISSIONS INVENTORY Comments related to the pollutant inventories used for the baseline and projected

emissions.

5. Comment: ACHD and MANE

- VU completed emissions inventory reviews and revisions with little or no input from sources other than U. S. Steel's Clairton Works. Since 2002 source testing and emissions inventory instructions have changed significantly; other than source testing at Clairton, ACHD and MANE

- VU did not included source testing data from any other sources. U. S. Steel is concerned about a possible unknown “smoking gun" sourceLiberty

- Clairton PM 2.5 SIP Revision April 2011 Page 94

or a combination of other sources that would cause the area to fail to achieve attainment, thereby requiring U. S. Steel to solely implement contingency measures.

Commenter : Coleen M. Davis, Senior Environmental Engineer, U. S. Steel Corporation.

Response : Most of the regional controls that will provide the majority of improvement in

PM 2.5 are form the sulfur dioxide and nitrogen oxides sources where emission factors and emission rates are well known. Local emission inventories were reviewed against ACHD inventories for accuracy. Furthermo re, the modeling results indicated that most sources outside of the immediate vicinity of the area did not show significant concentration gradients in comparison to specific U. S. Steel Clairton sources. Control of sources with small concentration gradien ts would show little or no relative reductions from baseline case to future projected case.

6. Comment: When Tables 6

- 1 and 6

- 2 are compared, it appears that ACHD anticipates emission increases for several pollutants for several types of sources, such as i ncreases of

PM 10 from area sources; increases of SO 2 from stationary point sources and area sources (which is anticipated to result in a total increase of SO 2 ); increases of NO

x from area sources; increases of VOCs from stationary point sources; and increa ses of ammonia from area

sources and mobile sources.

Commenter : Coleen M. Davis, Senior Environmental Engineer, U. S. Steel Corporation.

Response : Emissions inventories given in Tables 6

- 1 and 6

- 2 are for particulate matter and precursors from sources within the Liberty

- Clairton area only, and do not include the large amount of decreases expected from sources outside the area. The emissions inventory section has been revised on Page 20 of the SIP to more clearly indicate the represented area.

SO 2 and NO

x emissions from the larger modeled area are presented in Table 10

- 1.

7. Comment: The original and revised SIPs incorrectly use estimated reductions from distant power plants to demonstrate attainment. The original and revised SIPs estimate that

PM 2.5 levels in the Liberty

- Clairton area will decrease to some extent as a result of reductions in emissions from upwind power plants, even though in the SIP such emissions reductions are not shown to be from legally

- enforceable measures. Reductions may be incl uded in an attainment model only when they are as a result of such enforceable measures. Therefore, the original and revised SIPs are underestimating the amount of PM 2.5 from upwind sources that exists in the air in the Liberty

- Clairton area. This undere stimation may be exacerbated by the fact that emissions reductions from upwind power plants were likely to be attributable in significant part to implementation of the Clean Air Interstate Rule. Because that rule was vacated by a court decision in 2008, m any of the measures that power plants were planning to implement in order to comply with the rule have been delayed. Accordingly, the original and revised SIP may be underestimating the levels of PM 2.5 in Liberty

- Clairton from upwind

sources.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 95

Commenter : John K. Baillie, Senior Attorney, Citizens for Pennsylvania’s Future (PennFuture).

Response : The Pennsylvania CAIR rule was approved by EPA December 2009. Other states have implemented or are implementing their rules. EPA proposed the Transport Rule to replace CAIR in 2011. The Department fully expects the controls in the original CAIR or better to be implemented by the attainment date. PM 2.5 SIP modeling is a demonstration of predicted future actual impacts of the control strategy and expected act ual emission changes in the future. Emissions changes from EGUs include expected permit changes, shutdowns and constructions, federal limits, or local limits, and best

- estimated future actual operating levels and emissions. This follows the implementation guidance. The emission reductions are quantified in Appendices F

- H; emissions information from sources beyond the northeast has been added to Appendix G.

MODELING PROCEDURES Comments related to the methodology used for the baseline and projected dispe rsion modeling.

8. Comment: In Section 7.1.1, ACHD states that 2012 was selected in place of 2009 for the future to take advantage of regional sulfate/nitrate reductions; however, elsewhere in the documents, ACHD indicates that it expects emission increases for these pollutants in 2012. U. S. Steel would agree with ACHD's assertion that regional sulfate and nitrate reductions would be expected, but U. S. Steel questions the estimates provided in the SIP since they do

not reflect such reductions.

Commenter : Coleen M. Davis, Senior Environmental Engineer, U. S. Steel Corporation.

Response : Sulfate and nitrate components of PM 2.5 showed decreases from 2009 to 2012 based on long

- range regional modeling of SO 2 and NO

x precursors. There are no increases

of su lfate and nitrate expected during this timeframe. An annual increase of 81.32 tons of

SO 2 as a precursor by 2014 is shown in Table 6

- 2, but for the Liberty

- Clairton area only.

SO 2 as a precursor within the Liberty

- Clairton area does not represent upwind SO 2 that contributes to modeled particulate formation in SW PA.

9. Comment: In Table 7

- 1, ACHD shows an increase in surrounding counties that could impact the Clairton

- Liberty Borough area. U. S. Steel questions how these increases were determined and que stions their accuracy. If these estimates are accurate, U.S. Steel is concerned that the increases could cause the area to fail to reach attainment thus requiring U.S. Steel to implement contingency measures through no fault of U.S. Steel's.

Commenter : Coleen M. Davis, Senior Environmental Engineer, U. S. Steel Corporation.

Response : Increases in primary PM 2.5 emissions from background non

- EGU (electric generating unit) industrial sources in surrounding counties are based on growth factorsLiberty

- Clairton PM 2.5 SIP Revision April 2011 Page 96

developed f

or the MANE

- VU regional modeling effort. These sources do not show a significant modeled concentration gradient throughout the Liberty

- Clairton area. Increases in these surrounding counties represent 354 tons, compared to the overall decrease of 25,912

t ons from the most significant sources: those in Allegheny County, the West Virginia panhandle, and EGUs within the modeling domain.

10. Comment: Did ACHD account for stack parameter changes at EGUs that have installed

flue

- gas desulfurization projects in it s modeling analysis, for example Allegheny Energy's Hatfield's Ferry Power Station? Altered stack configurations at these sites may impact the Liberty

- Clairton PM

- 2.5 nonattainment area.

Commenter : Diana Esher, Director, Air Protection Division, U.S. EP A Region III.

Response : ACHD accounted for stack parameter changes at EGUs within the modeling domain. The revisions are described in Appendix H.

ATTAINMENT DEMONSTRATION Comments related to the assumptions and methodology used for the design value

ca lculations.

11. Comment: In Section 8.1, ACHD lists several assumptions that it used in its attainment demonstration. U. S. Steel questions how ACHD assumed that the Liberty speciation data is representative of both Liberty and Clairton. This is not consis tent with other claims made by ACHD. In addition, U. S. Steel questions the logic of this assumption if Clairton Works is

the main source of PM 2.5 . U. S. Steel asserts that this assumption is not accurately or adequately supported by the information prov ided in the proposed SIP revisions.

Commenter : Coleen M. Davis, Senior Environmental Engineer, U. S. Steel Corporation.

Response : Liberty PM 2.5 speciation data was used for the relative composition calculations for the Clairton site, which is a few mil es away. While the long

- term annual concentrations are lower at Clairton than at Liberty, it is assumed that high days

– specifically during variable or calm wind periods

– exhibit similar PM 2.5 compositions throughout the Liberty

Clairton area. The use of Liberty species compositions is appropriate for Clairton compositions.

12. Comment: The Clean Air Act requires state implementation plans to meet the air quality standard everywhere the public has access, not just the spots where pollution monitors ar e located. ACHD cannot show that the air in the Lincoln Area will meet federal air quality

standards. It seems counterintuitive that PM 2.5 levels will be the same in an area directly impacted by the stacks at the Clairton Works as they will be at a moni tor further downwind. EPA recommends additional pollution controls or placing monitors in the area of concern to better characterize the problem.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 97

Commenters : Joseph Osborne, Legal Director, The Group Against Smog and Pollution (GASP). John K. Baillie, Senior Attorney, Citizens for Pennsylvania’s Future (PennFuture).

Response : The controlling standard of this SIP is the annual standard, which is a community

- based standard. Analysis of the entire area will continue. ACHD will consider

whether additio nal monitors should be placed in this area upon annual network reviews.

ATTAINMENT DATE Comments related to the timeframe of the future projected attainment date and adequacy of extensions.

13. Comment: The PM 2.5 Implementation Rule requires the state to submit a mid

- course review by April 2011 for each area that cannot demonstrate attainment by 2014 in lieu of any other form of tracking reasonable progress. As a reminder EPA is requiring the state to

submit a mid

- course review, which shall include an upd ated attainment demonstration as well as a review of the implementation status of measures included in the SIP submittal, and review of recent air quality data.

Commenter : Diana Esher, Director, Air Protection Division, U.S. EPA Region III.

Response : A CHD recognizes the requirement for a mid

- course review based on the

attainment dates.

14. Comment: ACHD has not justified an extension from the April 5, 2010 attainment

deadline. The Clean Air Act states that an area may be exempted from that requirement for up to five years if there is a demonstration that all local control measures that are reasonably available and technically feasible for the area are currently being implemented to bring about expeditious attainment of the standard by the alternative at tainment date for the area. There has been no demonstration that local control measures could not be implemented sooner in the Liberty

- Clairton area.

Commenter : John K. Baillie, Senior Attorney, Citizens for Pennsylvania’s Future (PennFuture).

Response : The attainment plan includes the shutdown and replacement of expensive equipment at the U. S. Steel Clairton Coke Works. This is a complicated and extensive renovation, and as such, requires adequate time for safe and successful construction. The

sched ules had already been set within the construct of a consent order and agreement.

15. Comment: The Revised SIP cannot model actual attainment in 2015 based on monitor data from 2012, 2013, and 2014. In 2015, EPA will use air quality data from ACHD’s

monito rs in 2012, 2013, and 2014 to determine whether the Liberty

- Clairton area has attainedLiberty

- Clairton PM 2.5 SIP Revision April 2011 Page 98

the annual NAAQS for PM 2.5 . Because attainment in all parts of the Liberty

- Clairton area depends on implementation of the control measures at Clairton Works required by the amended consent order, and because those measures will not be implemented until the end of 2013, it appears that area will actually attain the standard.

Commenter : John K. Baillie, Senior Attorney, Citizens for Pennsylvania’s Future (PennFuture).

R esponse : The monitored attainment data will be based on one year of data for 2014, with subsequent years used for 3

- year periods. This is permissible under EPA regulations.

REASONABLE FURTHER PROGRESS Comments related to the analysis used to show reaso nable further progress toward attainment before the future projected attainment date.

16. Comment: The implementation rule requires the attainment plan to demonstrate that emissions will decline in a manner that represents generally linear progress from the 2002 baseline year to the attainment year. Table 10

- 4 shows the fraction of reductions achieved in each milestone year in order to demonstrate attainment of the 1997 PM 2.5 NAAQS. However, this section does not show the substitution ratio for PM 2.5 and th e precursor pollutants. This section should include the justification for your choice of substitution ratios. In doing so we suggest taking into account the relative proportion of the components comprising the total PM 2.5 mass at air quality monitors and considering the degree to which each PM component may contribute to PM 2.5 nonattainment.

Commenter : Diana Esher, Director, Air Protection Division, U.S. EPA Region III.

Response : No substitution was used in the Reasonable Further Progress section. De creases are demonstrated separately for each pollutant.

CONTINGENCY MEASURES Comments related to the additional contingency controls used in case the plan fails to demonstrate attainment by the attainment date.

17. Comment: U. S. Steel also respectfully di sagrees with ACHD's assertion that “the Liberty

- Clairton area is so small that sulfur dioxide and nitrogen dioxide do not have time to convert sulfates and nitrates. There is very little difference in sulfates and no difference in

nitrates measured at Lib erty from the monitors in the larger nonattainment area.” U. S. Steel believes that such a statement does not recognize the complexities associated with inversions

t hat occur in the Clairton area.

Commenter : Coleen M. Davis, Senior Environmental Enginee r, U. S. Steel Corporation.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 99

Response : Monitored data and supporting analyses for the baseline timeframe of 2000

- 2004 for this SIP indicated consistent trends for sulfates and nitrates throughout SW PA, with no outlying concentration variations at Liberty . If there was sufficient time for local conversion

of SO 2 and NO

x to sulfates and nitrates, there would have been sizeable differences in these levels compared to the Lawrenceville monitor. The Department will continue to investigate

the formation of su lfates and nitrates in SW PA in future PM 2.5 control plans.

18. Comment: U. S. Steel has concerns about the Department's and State's ability to enforce

the anti

- idling regulations to which both rely on in developing the SIP. U. S. Steel believes

that the r egulatory agencies will need to ensure that they appropriately enforce these requirements so that the anticipated reductions are realized.

Commenter : Coleen M. Davis, Senior Environmental Engineer, U. S. Steel Corporation.

Response : Due to the uncerta inty of emission reductions expected from enforcing the idling law, this was not included in the attainment demonstration, but rather discussed as further evidence of expected improvements to air quality.

19. Comment: The Department should have considered anticipated reductions that would be expected from anticipated mercury rules. U. S. Steel believes that the Department has not adequately addressed the impacts of such forthcoming regulations. In addition, U. S. Steel believes that the Department should recognize the anticipated replacement rule as a contingency measure.

Commenter : Coleen M. Davis, Senior Environmental Engineer, U. S. Steel Corporation.

Response : The uncertainty in the specifics of the federal replacement rule and the Pennsylvania m ercury regulations prevented this from being included in this SIP. Particulate improvements from this future rule will be considered in future PM 2.5 control plans.

20. Comment: ACHD calculated the contingency measure for PM 2.5 to be 87.8 tons/year.

Howev er, ACHD failed to quantify the emissions reductions associated with the contingency measures identified for 2009, and failed to identify any contingency measures for 2012. For areas requesting an extension of the attainment date beyond 2015, contingency measures are required for 2009, 2012 and 2015. Also, ACHD has noted that they are reserving the option to propose an alternative plan for contingency measures to be made final prior to the attainment date. Any changes ACHD makes must be submitted to EPA as a SIP revision.

Commenter : Diana Esher, Director, Air Protection Division, U.S. EPA Region III.

Response : Emission reductions sufficient for 2009 and 2012 have already been met with the permanent shutdown of Batteries 7

- 9 and Quench Tower 3 by mid

- 2 009. The SIP has been revised to reference the conditions of the consent order and agreement.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 100

TRANSPORTATION CONFORMITY Comments related to the determination that transportation projects will not impact the future attainment.

21. Comment: On page 68, ACHD indicates that much uncertainty remains regarding the role of NH3 in particulate formation. While U. S. Steel recognizes the challenges presented in determining the impacts of NH3 and its role in the formation of PM 2.5 in the area, U. S

Steel believes th at additional investigation in this area could be used to determine other potential contingency measures.

Commenter : Coleen M. Davis, Senior Environmental Engineer, U. S. Steel Corporation.

Response : The Department will continue to investigate the rol e of NH3 for future PM 2.5 control plans.

WEIGHT OF EVIDENCE Comments related to the supporting evidence used to show that the Liberty

- Clairton area shows decreasing trends of PM 2.5 .

22. Comment: The Department should consider a wood stove and wood

- fired bo iler program considered as a contingency measure. There are ample studies available in which quantifiable benefits from various programs are presented.

Commenter : Coleen M. Davis, Senior Environmental Engineer, U. S. Steel Corporation.

Response : The 2 005 woodstove exchange program did not have a significant impact on emission rates within the Liberty

- Clairton area. The Department may consider a more extensive woodstove exchange program as a possible control strategy or contingency

measure in a future SIP. Pennsylvania finalized an outdoor wood boiler regulation on October 2, 2010.

23. Comment: ACHD should review EPA's proposed Transport Rule to determine if the emission controls and schedules included in the rule would enhance the Liberty

- Clairton

PM 2. 5 nonattainment area's attainment prospects. A qualitative analysis of the proposed Transport Rule could be included in the Weight of Evidence section of the ACHD's SIP

document.

Commenter : Diana Esher, Director, Air Protection Division, U.S. EPA Region III.

Response : A comparison of EGU controls used in the Transport Rule compared to those used for the SIP modeling (CAIR controls) has been added to the weight of evidence section.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 101

Controls used in the proposed Transport Rule were found to be similar t o or better than the

modeled controls.

GENERAL

Comments related to the PM 2.5 SIP in general.

24. Comment: The emissions projections for the Clairton Works’ quench towers do not

account for PM 2.5 pollution caused by increasing levels of total dissolved soli ds in the Monongahela River. Solids dissolved in the river water may be emitted from the quench

towers as PM 2.5 . The river has experienced increased levels of total dissolved solids in the past several years, likely leading to increased PM 2.5 emissions f rom the quench towers, yet the original and revised SIPs assume that the water used in the quench towers is not impacted by high levels of total dissolved solids. ACHD and U.S. Steel should consider pre

- treating the river water used by the quench towers t o remove excess total dissolved solids and further

reduce Clairton Work’s PM 2.5 emissions.

Commenter : John K. Baillie, Senior Attorney, and Tiffany Hickman, Western PA Outreach Coordinator, Citizens for Pennsylvania’s Future (PennFuture).

Response : The emission rates for the quench towers were based on the estimates made during the permitting of these units , and t he control strategy for 2014 should not be modified on the basis of recent poor water quality. Pre

- treating the water would not advance

attai nment by a year

. ACHD will forward concerns over future water quality issues with the

PA DEP.

25. Comment: T

he revised SIP does not model attainment of the 2006 24

- hour NAAQS for fine particulate matter. Effective December 18, 2006, the 24

- hour NAAQS for fine particulate matter was reduced from 65 μg/m3 to 35 μg/m3. The revised SIP projects that the

24

- hour of fine particulate matter at the Liberty monitor will be 42 μg/m3, significantly in excess of the 35 μg/m3 standard

.

Commenter : John K. Baillie, Se nior Attorney, and Tiffany Hickman, Western PA Outreach Coordinator, Citizens for Pennsylvania’s Future (PennFuture).

Response : The nonattainment areas under the 35 μg/m3 24

- hour standard were made final in December 2009, which then require attainment pl ans to be developed by December 2012. The 35 μg/m3 implementation guidance has yet to be published, and the years to be used in the 35 μg/m3 plan are based around 2007 rather than 2002. Attainment of the 35 μg/m3

standard will be demonstrated in a future , separate SIP.

26. Comment: T

he original plan relied in part on an agreement between the County and US

Steel to shut down Clairton batteries 1

- 3 on the belief the batteries were in such poor condition they could not be brought into compliance. The revised SIP relies on a newLiberty

- Clairton PM 2.5 SIP Revision April 2011 Page 102

agreement with US Steel to repair the batteries and keep them operating. If these old batteries are to come into compliance through a course of repairs, US Steel must carry out the repair plan with maximum care and attention to detail, and County oversight of the repair work and battery performance should be just as vigilant.

Commenter : Joseph Osborne, Legal Director, The Group Against Smog and Pollution (GASP).

Response : ACHD agrees with this comment.

27. Comment: Additional measure s to reduce fine particulate matter pollution above and beyond those required by the amended Consent Order and Agreement still need to be determined and implemented. Such measures might include the accelerated construction of

new coke batteries at Clairto n Works and the accelerated shutdown or rebuild of old coke batteries. ACHD and U.S. Steel must also evaluate and implement additional measures to

limit PM 2.5 emissions from U.S. Steel’s J. Edgar Thomson Works, which is just upwind from the Liberty

- Clairt on area, and adds PM 2.5 pollution to the air in the Liberty

- Clairton area.

Commenter : John K. Baillie, Senior Attorney, and Tiffany Hickman, Western PA Outreach Coordinator, Citizens for Pennsylvania’s Future (PennFuture).

Response : The control strateg y as described in the SIP has been demonstrated in the SIP to be more than adequate to meet the standards.

28. Comment: The original and revised SIP fail to evaluate volatile organic compound (VOC) contribution to PM 2.5 formation. Although the Clean Air F ine Particle Implementation Rule presumes that control measures for VOCs need not be considered in a

SIP for PM 2.5 , that presumption does not apply if the agency that develops the SIP has information that shows that it is not technically justified. In th eir comments to the original SIP, PennFuture and GASP presented ACHD with information that demonstrates that the presumption that VOCs do contribute to PM 2.5 formation in the Liberty

- Clairton area.

ACHD should evaluate the contribution of VOCs to PM 2.5 po llution and include appropriate

control measures in the revised SIP.

Commenter : John K. Baillie, Senior Attorney, Citizens for Pennsylvania’s Future (PennFuture).

Response : The Pennsylvania Department of Environmental Protection (PA DEP) addressed

this issue for the entire Pittsburgh

- Beaver Valley region in its PM 2.5 SIP. PA DEP considered the data in the CMU report on air toxics in Allegheny County and other available data that EPA suggests would be appropriate to consider in developing a demonstratio n to reverse the default presumption that VOCs do not need to be included in the PM 2.5 attainment plan for the Pittsburgh

- Beaver Valley area. PA DEP concluded that there was too much uncertainty regarding the role of VOCs in the formation of fine particul ate to reverse theLiberty

- Clairton PM 2.5 SIP Revision April 2011 Page 103

presumption at this time. Since the Liberty

- Clairton area is small in size, and that VOCs require time to react in the atmosphere to create particulates, the Department has come to the

same conclusion.

29. Comment: T

he new plan will lea d to improved air quality sooner and below the margin of error. ACHD should continue working with industry in the Monongahela Valley and incorporate the concerns of the people into plans.

Commenters : A. Michele Tedder, MSN, RN, Community Outreach Direct or, Pediatric Environmental Medicine Center, Children's Hospital of Pittsburgh of UPMC. Patricia Jones, resident of the Mon Valley.

Response : ACHD appreciates all comments and will continue to control PM 2.5 in the Monongahela Valley.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 104



### 1 5

. 5. Cert ification s of Approval and AdoptionLiberty

- Clairton PM 2.5 SIP Revision April 2011 Page 105

The following certifications apply to the regulation changes to Allegheny County’s Article XXI in accordance with the previously submitted SIP revision (June 2010). These regulation changes were enacted by County O rdinance 11

- 10

- OR and became effective on May 24, 2010.Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 106Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 107Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 108Liberty

- Clairton PM 2.5 SIP Revision April 2011 Page 109



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