UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street

Philadelphia, Pennsylvania 19103-2029

	September 26, 2007



 ADVANCE \x15 SUBJECT:

	Technical Support Document for the Greenbrier   County, West Virginia
8-hour Ozone Section 110(a)(1) Maintenance Plan



 ADVANCE \x15 FROM:

	Irene Shandruk, Environmental Scientist

          /s/

 ADVANCE \x15 TO:

	WV-081; Docket No. EPA-R03-OAR-2007-0215

 ADVANCE \x15 THRU:

	Marilyn Powers, Acting Branch Chief      /s/

Air Quality Planning Branch



Background

In 1997, EPA promulgated a new form of the ozone standard, referred to
as 8-hour ozone, and in 2002, EPA began the process to designate areas
under the 8-hour ozone standard.  On June 15, 2004, EPA designated
Greenbrier County, West Virginia as attainment with respect to the
8-hour ozone standard.  This was the initial designation for Greenbrier
County, West Virginia and was based on 2001-2003 data.  Monitoring data
indicate that the Greenbrier County area had 8-hour ozone design values
of .08 ppm for the 2001-2003 period, .074 ppm or the 2002-2004 period,
.07 ppm for the 2003-2005 period, and has a design value of .068 ppm for
the 2004-2006 period.  Therefore, Greenbrier County remains in
attainment with the 8-hour ozone NAAQS. 

Section 110(a)(1) of the Clean Air Act (CAA or Act) requires that areas
that were maintenance areas for the 1-hour ozone NAAQS but attainment
for the 8-hour ozone NAAQS submit a plan to demonstrate the continued
maintenance of the ozone NAAQS.  These plans were due to EPA on June 15,
2007, three years after the effective date of the initial 8-hour ozone
designations.

On December 4, 2006, the EPA received a request from the West Virginia
Department of Environmental Protection (WVDEP) for approval of the
Section 110(a)(1) 8-hour Ozone Maintenance Plan for Greenbrier County,
West Virginia as a revision to the State Implementation Plan (SIP). This
plan demonstrates how the state intends to maintain the 8-hour NAAQS for
ozone.  Additionally, WVDEP requested that pursuant to 40 CFR
51.905(e)(1), EPA concurrently approve two amendments to the existing
1-hour ozone maintenance plan: (1) removal of the obligation to submit a
maintenance plan for the 1-hour NAAQS 8 years after approval of the
initial 1-hour maintenance plan; and (2) removal of the State’s
obligation to implement contingency measures upon a violation of the
1-hour NAAQS.  West Virginia’s SIP submittal meets the CAA
requirements for SIP submittals under Section 110(a)(1).

What are the components of a Section 110(a)(1) 8-hour ozone maintenance
plan?

On May 20, 2005, EPA issued guidance that applies to areas that are
designated attainment/unclassifiable for the 8-hour ozone standard and
that had an approved 1-hour ozone maintenance plan.  The purpose of this
guidance, referred to as Section 110(a)(1) guidance, is to assist the
states in the development of a SIP which addresses the maintenance
requirements found in Section 110(a)(1) of the CAA.  The components of
the Section 110(a)(1) maintenance plan include:

Attainment Inventory - The inventory should be based on actual typical
summer day emissions of volatile organic compounds (VOCs) and nitrogen
oxides (NOx) for a 10-year period from a base year as chosen by the
state.

Maintenance Demonstration - The demonstration should show how the area
will remain in compliance with the 8-hour ozone standard for 10 years
following the base year following the effective date of designation
(June 15, 2004).  

Ambient Air Quality Monitoring - The state should continue to operate
air quality monitors in accordance with 40 CFR Part 58 to verify
maintenance of the 8-hour ozone standard.  

Contingency Plan - The state must develop a contingency plan that will
ensure that a violation of the 8-hour ozone NAAQS is promptly addressed.
 

Verification of Continued Attainment - The state should indicate how the
state will track the progress of the maintenance plan.  This is due to
the fact that emissions projections depend on assumptions of point,
area, and mobile sources emissions.

How has the state addressed the components of a Section 110(a)(1) 8-hour
ozone maintenance plan?

Attainment Inventory – WVDEP has provided a comprehensive and current
emissions inventory for NOx and VOCs. WVDEP has chosen to use 2002 as
the base year from which it will project emissions.  Since the effective
date of the 8-hour ozone initial designation was June 15, 2004, WVDEP is
required to project emissions for 10 years from the effective date of
initial designations.  As such, WVDEP has projected emissions for the
year 2014.  In the maintenance plan, West Virginia includes the
methodology used for determining the anthropogenic (area and mobile
sources) emissions.  There are no Title V point sources located in
Greenbrier County, so a 2002 point source inventory was not compiled.
The inventory is based on emissions from a typical ozone season day. 
The term “typical” refers to emissions being emitted during a
typical weekday during the months where ozone concentrations are
typically the highest.  The table below shows total anthropogenic
emissions in Greenbrier County.

Emissions for Greenbrier County in Tons/Day for an Ozone Season Day

YEAR	NOx	VOCs

2002	7.4	7.7

2014	4.9	7.0



Maintenance Demonstration – As the table above indicates, the total
emissions are projected to decrease during the 10-year maintenance
period.  The plan has demonstrated that, from an emissions projections
standpoint, it is anticipated that emissions will be decreasing. 
However, it is important to note that the formation of ozone is
dependent on a number of variables which cannot be estimated through
emissions growth and reduction calculations.  A few of these variables
include weather and the transport of ozone precursors from outside the
maintenance area.

Ambient Air Quality Monitoring – WVDEP commits to continue operating
air quality monitoring stations in accordance with 40 CFR Part 58
throughout the maintenance period to verify maintenance of the 8-hour
ozone standard, and will submit quality-assured ozone data to EPA
through the AIRS system.

Contingency Plan – Section 110(a)(1) of the CAA requires that the
state develop a contingency plan which will ensure that any violation of
a NAAQS is promptly corrected. The purpose of the contingency measures,
as outlined in West Virginia’s maintenance plan, is to accordingly
select and adopt one or more measures outlined in the maintenance plan
so as to assure continued attainment in the event that a violation of
the ozone NAAQS is measured.  Violation of the 8-hour ozone standard,
once quality assured, would trigger one or more of the following control
measures, which are to be implemented within 18 months from the time a
violation occurs:

Extend the applicability of 45CSR21 (VOC/RACT rule) to include
Greenbrier County.

Revise new source permitting requirements requiring more stringent
emissions control technology and/or emissions offsets.

NOx RACT requirements if necessary.

Regulations to establish plant-wide emission caps (potentially with
emissions trading provisions).

Stage II Vapor Recovery regulations.

Establish a Public Awareness/Ozone Action Days Program, a two-pronged
program focusing on increasing the public’s understanding of air
quality issues in the region and increasing support for actions to
improve the air quality, resulting in reduced emissions on days when the
ozone levels are likely to be high.

Initiate one or more of the following voluntary local control measures:

Bicycle and Pedestrian Measures – A series of measures designed to
promote bicycling and walking including both promotional activities and
enhancing the environment for these activities.

Reduce Engine Idling – Voluntary program to restrict heavy-duty diesel
engine idling times for both trucks and school buses.

Voluntary Partnership with Ground Freight Industry – a voluntary
program using incentives to encourage the ground freight industry to
reduce emissions.

Increase Compliance with Open Burning Restrictions – Increase public
awareness of the existing open burning restrictions and work with
communities to increase compliance.

School Bus Engine Retrofit Program – Have existing school bus engines
retrofitted to lower emissions.

Verification of Continued Attainment - In the section 110(a)(1)
maintenance plan, WVDEP has indicated that the state will track the
progress of the maintenance plan by updating the emissions inventory for
the Greenbrier County area approximately every three years.  The
emissions inventory update will include point, area, and mobile source
emissions. Information from these future updates will be compared with
the projected growth estimates for the 2002 base inventory data to
ensure that the standard is maintained.

Recommendation

The state has met the requirements to submit a Section 110(a)(1)
maintenance plan and has adequately addressed the components of a
Section 110(a)(1) plan.  Therefore, approval of West Virginia’s 8-hour
Ozone Maintenance Plan is recommended. Additionally, concurrent with the
approval of the State’s 110(a)(1) plan, it is recommended that the two
requested amendments of (1) removal of the obligation to submit a
maintenance plan for the 1-hour NAAQS 8 years after approval of the
initial 1-hour maintenance plan, and (2) removal of the State’s
obligation to implement contingency measures upon a violation of the
1-hour NAAQS be approved as a revision to West Virginia’s SIP.  

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