EPA-450/3-75-020

FEBRUARY 1975
     IMPLEMENTATION PLAN REVIEW
                  FOR
           WEST VIRGINIA
              AS REQUIRED
                   BY
          THE ENERGY  SUPPLY
                  AND
   ENVIRONMENTAL COORDINATION ACT
     U. S. ENVIRONMENTAL PROTECTION AGENCY

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                                                              EPA-450/3-75-020
                     IMPLEMENTATION PLAN REVIEW

                                FOR

                           WEST VIRGINIA

AS REQUIRED BY THE ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT
               PREPARED BY THE FOLLOWING TASK FORCE:

         U. S. Environmental Protection Agency, Region III
                       6th and Walnut Streets
                  Philadelphia, Pennsylvania 19106
                Environmental Services of TRW, Inc.
           800 Follin Lane, SE, Vienna, Virginia 22180
                       (Contract 68-02-1385)
               U. S. Environmental Protection Agency
                Office of Air and Waste Management
            Office of Air Quality Planning and Standards
            Research Triangle Park, North Carolina 27711
                             February  1975

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                              WEST VIRGINIA
             ENERGY SUPPLY AND ENVIRONMENTAL COORDINATION ACT
             (SECTION IV - STATE IMPLEMENTATION PLAN REVIEW)
                            Table of Contents                           Page
1.0  EXECUTIVE SUMMARY 	   1
2.0  STATE IMPLEMENTATION PLAN REVIEW 	  5
   2.1   Summary	5
   2.2   Air Quality Setting - State of West Virginia	10
   2.3   Background on the Development of West Virginia's
        Current State Implementation Plan	12
   2.4   Special Considerations 	  13
3.0  CURRENT ASSESSMENTS BASED ON STATE IMPLEMENTATION PLAN REVIEW ...  15
   3.1   Air Quality Control Region #103, Huntington - Ashland -
        Portsmouth - Ironton (Kentucky - Ohio) 	  16
   3.2   Air Quality Control Region #113, Cumberland - Keyser  (Maryland)  .17
   3.3   Air Quality Control Region #179, Parkersburg - Marietta (Ohio)  .  18
   3.4   Air Quality Control Region #181, Steubenville - Weirton -
        Wheeling (Ohio)	19
   3.5   Air Quality Control Region #231, Allegheny 	  ....  20
   3.6   Air Quality Control Region #232, Central  West Virginia 	  21
   3.7   Air Quality Control Region #233, Eastern Panhandle 	  22
   3.8   Air Quality Control Region #234, Kanawha Valley	  .   23
   3.9   Air Quality Control Region #235, North Central  West Virginia .  .  24
   3.10 Air Quality Control Region #236, Southern West Virginia ....   25
                                                                         27
 APPENDIX A - STATE IMPLEMENTATION PLAN BACKGROUND
 APPENDIX B - REGIONAL ASSESSMENT
                                                                         39
 APPENDIX C - POWER PLANT ASSESSMENT
 APPENDIX D - INDUSTRIAL FUEL COMBUSTION SOURCE LISTING                  43
 APPENDIX E - AQCR FUEL USE                                              45
                               iii

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                         1.0  EXECUTIVE SUMMARY

     The enclosed report 1s the U. S. Environmental Protection Agency's
(EPA) response to Section IV of the Energy Supply and Environmental Coordin-
ation Act of 1974 (ESECA).  Section IV requires EPA to review each State
Implementation Plan (SIP) to determine If revisions can be made to control
regulations for stationary fuel combustion sources without interfering with
the attainment and maintenance of the National Ambient Air Quality Standards
(NAAQS).  In addition to requiring that EPA report to the State on whether
control regulations might be revised, ESECA provides that EPA must approve
or disapprove any revised regulations relating to fuel burning stationary
sources within three months after they are submitted to EPA by the States.
The States may, as in the Clean Air Act of 1970, initiate State Implementa-
tion Plan1' revisions; ESECA does not, however, require States to change any
existing plan.

     Congress has intended that this report provide the State with informa-
tion on excessively restrictive control regulations.  The intent of ESECA is
        J'v .
that SIP'-s, wherever possible, be revised in the interest of conserving low
sulfur fuels or converting sources which burn oil or natural gas to coal.
EPA's objective in carrying out the SIP reviews, therefore, has been to try
to establish if emissions from combustion sources may be increased.  Where
an indication can be found that emissions from certain fuel burning sources
can be increased and still attain and maintain NAAQS, it may be plausible
that fuel resource allocations can be altered for "clean fuel savings" in a
        I                                                     •
manner consistent with both environmental and national energy needs.

     In many respects, the ESECA SIP reviews parallels EPA's policy on clean
fuels.  The Clean Fuels Policy has consisted of. reviewing implementation plans
with regards to saving low sulfur fuels and, where the primary sulfur dioxide
air quality standards were not exceeded, to encourage States to either defer
compliance regulations or to revise the S0£ emission regulations.   The States
have also been asked to discourage large scale shifts from coal to oil where
this could be done without jeopardizing the attainment and maintenance of
the NAAQS.

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       To date, EPA's fuels policy has addressed only those States with the
largest clean fuels saving potential.  Several of these States have or are
currently in the process of revising S02 regulations.  These States are gen-
erally in the Eastern half of the United States.  ESECA, however, extends
the analysis of potentially over-restrictive regulations to all 55 States
and territories.  In addition, the current reviews address the attainment
and maintenance of all the National Ambient Air Quality Standards.

       There are, in general, four predominant reasons for the existence of
overly restrictive emission limitations within the State Implementation Plans.
These are (1) the state's prerogative to surpass NAAQS; (2) the use of the
example region approach in developing State-wide air quality control strategies;
(3) the existence of state air quality standards which are more stringent
than NAAQS; and (4) the "hot spots" in only part of an Air Quality] Control
Region (AQCR) which have been used as the basis for controlling the entire
region.  Since each of these situations effect many State plans and in some
instances conflict with current national energy concerns, a review of the
State Implementation Plans is a logical follow-up to^EPA's initial appraisal
of the SIP's conducted in 1972.  At that time SIP's were approved Iby EPA if
they demonstrated the attainment of NAAQS p_r more stringent state 

       The example region concept permitted a State to identify the most pol-
luted Air Quality Control Region (AQCR) and adopt control regulations which
                                                                  *
would be adequate to attain the NAAQS in that region.  In using an example
region, it was assumed that NAAQS would be attained in the other AQCR's of
the State if the control regulations were applied to similar sources.  The
problem with the use of an example region is that it can result in controls
which are more stringent than needed to attain NAAQS, especially in the util-
ization of clean fuels, for areas of the State where sources would not other-
wise contribute to NAAQS violations.  For instance, a control strategy based
on a particular region or source can result in a regulation requiring 1 per-
cent sulfur oil to be burned state-wide where the use of 3 percent sulfur coal
would be adequate to attain NAAQS in some locations.

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             \
        EPA  anticipates that a number of states will use the review findings
to assist them in making $ie decision whether or not to revise portions of
their State  Implementation Flans.  However, it is most important for those
States which desire to submit a  revised plan to recognize the review's lim-
itations.  The findings of this  report are by no means conclusive and are
neither intended nor adequate to be the sole basis for SIP revisions; they
do, however, represent EPA's best judgment and effort in complying with the
ESECA requirements, j The time and resources which EPA has had to prepare
the reports  has not pe'rmitted' the consideration of growth,, economics, and
control strategy tradeoffs.  Also, there has been only limited dispersion
modeling data available by which to address individual point source emis-
.sions.  Where the modeling data  for specific sources were found, however,
they were used in the analysis.

        The  data upon which the  reports' findin'gs are based are the most cur-
rently available to the Federal  Government.  However, EPA believes that the
States possess the best information for developing revised plans.  The States
have the most up-to-date ai%quality and emissions data, a better feel for
growth, and  the fullest understanding for the complex problems facing them
in the attainment and maintenance of air quality.  Therefore, those States
desiring to  revise a plan are encouraged to verify and, in many instances,
expand the modeling and monitoring data supporting EPA's findings.  In dev-
eloping a suitable plan, it is suggested that States select control strategies
which place  emissions for fuetl combustion sources into perspective with all
sources of emissions s-uch as smelters or other industrial processes.   States
are encouraged to consider the overall impact which the potential relaxation
of overly restrictive emissions  regulations for combustion sources might have
on their future control programs.  This may include air quality maintenance,
prevention of significant deterioration, increased TSP, NO , and HC emissions
          i                                                x
which occ|r  in fuel switching and other potential air pollution situations
such as sulfates.

        Although the enclosed analysis has attempted to address the attainment
of all NAAQS, most of the review has focused on total suspended particulate
matter (TSP) and sulfur dioxide  (S0?) emissions.  This is because stationary
fuel combustion sources constitute the greatest source of SOp emissions and
are a major  source of TSP emissions.

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     Part of each State's review was organized to provide an analysis of

the $62 and TSP emission tolerances within each of the various AQCRs.  The

regional emission tolerance estimate is, in many cases,. EPA's only measure

of the "over-cleaning" accomplished by a SIP.   The tolerance assessments

have been combined in Appendix B with other regional  air quality "indicators";,

in an attempt to provide an evaluation of a region's  candidacy for changing

emission limitation regulations.  In conjunction with the regional analysis,

a summary of the State's fuel combustion sources (power plants, industrial

sources, and area sources) has been carried out in Appendices C, D, and E.


     The State Implementation Plan for West Virginia  has been reviewed for

the most prevalent causes of over-restrictive  fuel combustion limiting regu-

lations.  The major findings of the review are:

     FOR TOTAL SUSPENDED PARTICIPATES, THERE IS LITTLE INDICATION THAT
     EXISTING FUEL COMBUSTION SOURCE EMISSION  LIMITING REGULATIONS ARE
     OVER-RESTRICTIVE

     FOR SULFUR DIOXIDE. THERE IS LITTLE INDICATION THAT EXISTING FUEL
     COMBUSTION SOURCE EMISSION LIMITING REGULATIONS  ARE OVER-RESTRICTIVE


     The supportive findings of the SIP review are as follows:

     Like many other areas of the nation, high levels of total suspended
     particulates were found in many of the AQCRs during 1973.  Fuel  com-
     bustion sources contribute a majority of  the particulate emissions
     in many of the AQCRs, therefore a relaxation of  existing particulate
     emission regulations may adversely affect existing air quality.

     In many areas within the State, power plants are contributing a  large
     percentage of the sulfur dioxide emissions and any relaxation of the
     SOo emission limits for these sources would have a significant adverse
     effect on existing air quality.  Additional air  quality data for sulfur
     dioxide are needed in most of the AQCRs before any regulation relaxation
     is considered.  Many of the AQCRs are classified priority III for this
     pollutant and were not required to have air monitors during 1973.

     Recent action by the State of West Virginia parallels  the indention
     of Section IV of ESECA.  In an attempt to reduce the impact of fuel
     shortages, and to conserve clean fuel, the State submitted a plan
     revision which would relax the regulations to permit the maximum dis-
     charge of sulfur dioxide to be 45,000 pounds per hour  rather than
     32,000 pounds per hour from all sources in a given facility.  The
     impact of this change in regulations affects only one  large power
     plant.

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                  2.0  STATE IMPLEMENTATION PLAN REVIEW
2.1  SUMMARY
     A revision of fuel  combustion source emissions regulations will  depend

on many factors.

     •  Does the State have air quality standards which are more stringent
        than NAAQS?

     •  Does the State have emission limitation regulations for control  of
        (1) power plants, (2) industrial sources, (3) area sources?

     •  Did the State use an example region approach for demonstrating the
        attainment of NAAQS cir more stringent State standards?

     •  Has the State not initiated action to modify combustion source
        emission regulations for fuel  savings; i.e., under the Clean
        Fuels Policy?

     •  Are there no proposed Air Quality Maintenance Areas?

     t  Are there indications of a sufficient number of monitoring sites
        within a region?

     •  Is there an expected 1975 attainment date for NAAQS in the State
        Implementation Plan?

     •  Based on (1973) air quality data, are there no reported violations
        of NAAQS?

     •  Based on (1973) air quality data, are there indications of a
        tolerance for increasing emissions?

     •  Are the total emissions from stationary fuel combustion sources
        proportionally lower than those of other sources?

     •  Do modeling results for specific fuel combustion sources show a
        potential for a regulation revision?


     The following portion of this report is directed at answering these
questions.  An AQCR's potential for revising regulations increases when  there

are affirmative responses to the above.


     The initial part of the SIP review report, Section 2 and Appendix A,

was organized to provide the background and current situation information

for the State Implementation Plan.  Section 3 and the remaining Appendices

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provide an AQCR analysis which helps establish the overall potential  for
revising regulations.
     Based on an overall evaluation of EPA's current information, AQCR's have
been rated as either a good, poor or marginal candidate for revising emission
limiting regulations.  These ratings which are shown in Table 2-1 were deter-
mined by assessing the following criteria:
         Good
1) Adequate number
   of air monitoring
   sites
2) No NAAQS violations
3) Attainment date of
   1975 for NAAQS in
   the SIP
4) No proposed AQMAs
5) Modeling results
   show a potential
   for regulation
   revision
       Poor
1) Violation of NAAQS
2) Attainment date for
   NAAQS later than
   1975
3) Proposed AQMA
4) Modeling results
   show no potential
   for regulation
   revision
     Marginal
1) No air quality data
   or insufficient number
   of monitoring sites
2) Inconsistent
   "indicators"
     For an AQCR to be rated as a good candidate, all  of the criteria listed
under "Good" would have to be satisfied.   The overriding factor in rating an
AQCR as a poor candidate is a violation of either the  primary or secondary
National Ambient Air Quality Standards during 1973.  However, if any of the
other conditions listed under "Poor" exists, the AQCR  would still  receive
that rating.  The predominant reason for a marginal  rating is a lack of suf-
ficient air quality data.  In Priority III regions,  air monitoring was  not
required during 1973, therefore, there are little if any data with which to
determine the current air quality status.   Marginal  ratings are also given
when there are varying or inconsistent "indicators".
     After a candidacy has been given to a region,  a follow-up  analysis  should
be conducted depending on the rating.  A region that has  been indicated  to  be
a good candidate for regulation revision should be  examined  in  more  detail
by the state and the Regional office of the EPA, including an examination of
current air quality, emissions, and fuel use data,  with which the  state  has

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more familiarity.  If the state feels that clean fuels could be saved in a
region rated marginal then an analysis of air quality data that may have
become available since this report should be examined.  If current data do
not indicate a potential for regulation revision then further study would
not be warranted.  An AQCR that has been indicated to be a poor candidate
would not warrant further study unless the state feels that new information
has become available indicating that the poor rating is no longer valid.

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                                                                                                           STATE IMPLEMENTATION PLAN REVIEW
                                                                                                                       (SUMMARY)
  •  Does the State have air quality standards
which are more stringent than NAAQS?

  •  Does the State have emission limiting regu-
lations for control of:

     1. Power plants
     2. Industrial sources
     3. Area sources

  •  Did the State use an example region approach
for demonstrating the attainment of NAAQS or
more stringent State standards?

  •  Has the State not initiated action to modify
combustion source emission regulations for fuel
savings; i.e., under the Clean Fuels Policy?
  •  Are there no proposed Air Quality Maintenance
Areas?
  •  Are there indications of a sufficient number
of monitoring sites within a region?
  •  Is there an expected 1975 attainment date
for NAAQS in the State Implementation Plan?f

  •  Based on (1973) Air Quality Data, are there
no reported violations of NAAQS?

  •  Based on (1973) Air Quality Data, are there
indications of a tolerance for increasing emissions?

  •  Are the total emissions from stationary fuel
combustion sources proportionally lower than those
of other sources?
  •  Do modeling results for specific fuel combustion
sources show a potential for a regulation revision?

  •  Based on the above indicators, what is the poten-
tial for revising fuel combustion source emission
limiting regulations?
Huntington Cumberland Parkersburg Steubenville
Ashland Kevsar Marietta Weirton Allegheny Central W. Va.
State H. Va AQCR 103 AQCR 113 AQCR 179 AQCR 181 AQCR 231 AQCR 232
TSPSO^TSPSOzTSPSOjJSPSOjTSPSO^ TSP 50^ TSP SOj
No Yes*
Yes Yes
Yes Yes
Yes Yes
Yes Yes
Yes Nob


Ho Yes No Yes No H.A. No No N.A. N.A. N.A. N.A.
No Yes No Yes No N.A. No No N.A. N.A. N.A. N.A.
N.A. No N.A. Yes N.A. No No Yes N.A. N.A. N.A. N.A.
d
Poor Marg. Poor Farg. Poor Marg. Poor Poor Marg. Marg. Marg. Marg.
Eastern Panhandle Kanawha Valley
AQCR 233 AQCR 234
TSP SQ2 TSP S02






H.A. N.A. No Yes
N.A. N.A. No Yes
N.A. H.A. H.A. N.A.
Marg. Marg. Poor Marg.
North Central
W. Va. Southern W. Va.
AQCR 235 AQCR 236
TSP SQg TSP SO?






Yes N.A. No N.A.
Yes N.A. No N.A.
N.A. Yes N.A. N.A.
Poor Marg. Poor Harg.
aThe state has adopted secondary standards for sulfur dioxide.

 Relaxing SOg emission limits will affect one large power plant.
cNo monitors in West Virginia portion of A*]CR

 One power plant was involved in a controversy concerning damage  to Christmas  trees.

 Priority III regions not required to have air monitors until  two years after SIP  is  approved.
  Attainment dates are for primary and secondary standards.

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           PARKERSBURG-
           MARIETTA
           INTERSTATE>
           (WEST VIRGINIA7
           OHIO)
STEUBENVILLE
WEIRTON-
WHEELING
INTERSTATE
(OHIO-
WEST VIRGINIA)
CUMBERLAND-
KEYSER
INTERSTATE
(WEST VIRGINIA-
MARYLAND)
HUNTINGTON
ASHLAND-
PORTSMOUTH-
IRONTON
INTERSTATE
(WEST VIRGINIA
KENTUCKY-
OHIO)
  SOUTHERN
  WEST VIRGINIA
  INTRASTATE
NORTH CENTRAL
WEST VIRGINIA
INTRASTATE
             KANAWHA
             VALLEY
             INTRASTATE
                                                                      ALLEGHENY
                                                                      INTRASTATE
                                                             CENTRAL
                                                             •WEST VIRGINIA
                                                             INTRASTATE
                                                         EASTERN
                                                         PANHANDLE
                                                         INTRASTATE
          Figure  2-1   WEST VIRGINIA AIR QUALITY  CONTROL REGIONS

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2.2  AIR QUALITY SETTING - STATE OF WEST VIRGINIA
2.2.1  West Virginia Air Pollution Control Areas
       The State of West Virginia has been divided into ten Air Quality
Control Regions (AQCR) as follows:
       Huntington - Ashland - Portsmouth - Ironton Interstate (Kentucky, Ohio)
       Cumberland - Keyser Interstate (Maryland)
       Parkersburg - Marietta Interstate (Ohio)
       Steubenville - Weirton - Wheeling Interstate (Ohio)
       Allegheny  Intrastate
       Central West Virginia Intrastate
       Eastern Panhandle Intrastate
       Kanawha Valley Intrastate
       North Central West Virginia Intrastate
       Southern West Virginia Intrastate
       These regions are also shown on Table A-l, along with the priority
classifications for total suspended particulates and sulfur dioxide, and
an estimate of the 1975 population in each AQCR.  There are no Air Quality
Maintenance Areas proposed at this time.

2.2.2  Ambient Air Quality Standards
       West Virginia has established ambient air quality standards for sus-
pended particulates and sulfur dioxide.   These standards which are shown in
Table A-2 are the same as the Federal standards, except that the state has
established secondary annual and 24-hour standards for sulfur dioxide.

2.2.3  West Virginia Air Quality Status
       West Virginia Air Quality for 1973 is summarized in Table A-3 and
A-4 for suspended particulates and sulfur dioxide respectively.   These data
are from the SAROAD data bank, July 28,  1974.  It should be noted not all
of the air quality data collected by the state are necessarily in the data
bank.

       Total  suspended particulate data  are available  for seven  of the ten
Air Quality Control  Regions.   There are  no air monitoring data for the
Allegheny, Central  West Virginia, and Eastern Panhandle regions.   These
regions are all  classified as Priority III for particulates,  and  are not
                                    10

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required to establish air monitors until two years after the State Imple-
mentation Plan is approved.  The Southern West Virginia AQCR is also a
Priority III region however air quality data for suspended particulates
are available.  Table A-3 shows that of the seven regions monitoring par-
ti culates, five regions require a significant reduction in the 1973 levels
in order to attain air quality standards, while one region requires a
minimal reduction, and one region has a tolerance for an increase in am-
bient levels and still maintain standards.  The highest concentration in
West Virginia for an annual geometric mean was 73 yg/m3, and for the maxi-
mum 24-hour average, 475 yg/m3, recorded in the Huntington - Ashland -
Portsmouth - Ironton region and the Steubenvil'le - Weirton - Wheeling re-
gion respectively.  Suspended particulate levels are generally consistent
with priority classifications as the regions that are reporting air quality
violations have a Priority I classification.

       Sulfur dioxide is monitored in four of the ten AQCR's, however there
are seven regions that are classified Priority III for this pollutant, and
again, monitoring was not required in these regions during 1973.  As indi-
cated in Table A-3, three regions; the Huntington - Ashland - Portsmouth -
Ironton, the Cumberland - Keyser, and the Kanawha Valley, have a tolerance
for an increase in 1973 ambient levels and still maintain standards.  How-
ever, supplemental information as reviewed in Section 2.1 indicates that
these regions are only marginal candidates for regulation revision.

2.2.4  West Virginia Emissions Summary
       A summary of particulate and sulfur dioxide emissions for each of the
regions is presented in Table A-6 and A-7 respectively.  These data are from
the State Implementation Plan Emission Inventory and are representative of
fiscal year 1971.  In some cases, data from the "1972 National Emissions
Report" June 1974 were used.

       Table A-5 is a summary of fuel combustion sources listing the number
of power plants and major fuel combustion sources in each region and the per-
centage of t&e total emissions in each AQCR that are a result of fuel combustion.
As shown on this table, fuel combustion sources account for the majority of
                                      II

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both particulate and sulfur dioxtde emissions in several of the regions, indi-
cating that a relaxation in emission regulations may have a significant adverse
impact on air quality.

       The greatest amount of particulate and sulfur dioxide emissions are
found in the Steubenville-Weirton-Wheeling AQCR, which has two power plants
and several industrial fuel combustion sources in operation.  The Kanawha
Valley and the North Central West Virginia AQCR contribute the second highest
amount of particulate and sulfur dioxide emissions.

2.3  BACKGROUND ON THE DEVELOPMENT OF WEST VIRGINIA'S CURRENT STATE
     IMPLEMENTATION  PLAN
2.3.1  Control Strategy for Particulate Matter and Sulfur Oxides
       The Kanawha Valley  Intrastate and Steubenville - Weirton -
Wheeling  Interstate  Regions were designated as the example regions for
the development of the control strategies for particulate matter in all
Priority  I regions (there  are no Priority II regions) and for sulfur
oxides in Priority I and Priority II regions, respectively.  These
regions were selected as example regions due to their high emissions,
poor air quality, and similarity to the other regions.  West Virginia
shows attainment and maintenance of the national standards for particulate
matter and sulfur oxides through the use of a proportional model. Growth
factors, based on EPA data, and planned growth and economic projections
were applied to each category of emission sources to determine projected
emissions after application of the adopted emission limitations.  Since
the projected emissions are less than that which were designed to attain
the national standards in  the example regions, the national standards should
be attained in all Priority I regions for particulate matter and in all
Priority  I and Priority II  regions for sulfur oxides.  The capability of
denying permits for  the construction of new sources or the modification of
existing sources, the Federal Standards of Performance of New Stationary
Sources and the application of the state-wide emission limitations are de-
signed to prevent ambient  pollution levels from exceeding secondary standards
for sulfur oxides and particulate matter in all regions.
                                    12

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2.4  SPECIAL CONSIDERATIONS
        A revision to the West Virginia Implementation  Plan was  approved
on August 12, 1974.   This revision relaxes  the regulations  to  permit  the
maximum discharge of sulfur dioxide to be 45,000 pounds per hour rather
than 32,000 pounds per hour from all  sources  in  a given facility.   The
impact of this change affects only one large  power plant.
                                    13

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   3.0  CURRENT ASSESSMENTS BASED ON STATE IMPLEMENTATION PLAN REVIEW
     The purpose of this section is to evaluate the available information
for the State of West Virginia and determine the feasibility of revisions
to the SIP which would result in clean fuel conservation.  The assessments
will be made by AQCR, addressing each type of fuel combustion source:  power
plants, large industrial and commercial/institutional  sources, and area
sources.  The assessments must be made for each pollutant separately and
are made on the basis of seven criteria:  (1) 1973 air quality violations;
(2) expected NAAQS attainment dates; (3) proposed Air Quality Maintenance
Area (AQMA) designations; (4) total emissions; (5) portion of emissions from
West Virginia fuel combustion sources; (6) regional tolerance for emissions
increase; and (7) pollutant priority classifications.   Tables B-l and B-2
tabulate these criteria for each AQCR for TSP and S02, respectively.

     Table C-l shows the 1973 fuel use and sulfur content of the fuel for
each power plant.  The sulfur content is an average content for the year,
as variations of up to 20% are common.  This information is from the Federal
Power Commission and was used in place of the NEDS data since it is more
current.  Also shown in this table is the projected fuel use for 1975 for
each plant, and the sulfur content of the fuel as required by the State
Implementation Plan.  Allowable sulfur content determined by modeling results
are also shown.1  There are limitations to be considered in using modeling
results, because often assumptions are made in the input to the model, when
actual  data are not available.  Modeling results are presented here as another
indicator in assessing the candidacy of a region to revise emission regulations,

     Appendix  D shows the major industrial fuel  combustion sources which
were significant emitters of particulates and sulfur dioxide when the emis-
sions inventory was conducted for the West Virginia State Implementation Plan.
  The modeling analysis of the power plants was performed by the Walden
  Research Division of Abcor, Inc.  A single-source and valley model,
  developed by the Meteorology Laboratory, EPA, was used.  The model employs
  a Gaussian plume model and Briggs plume rise equation.  Comments on the
  use of the model are included in Appendix C.
                                     15

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3.1   AIR QUALITY CONTROL REGION #103,  HUNTINGTON-ASHLAND-PORTSMOUTH-IRONTON
     (KENTUCKY, OHIO)

3.1.1  Regional Air Quality Assessment
        Ambient air levels of total  suspended participates  exceeded both  the
annual and 24 hour secondary standards in the West Virginia portion of this
AQCR during 1973 (Table A-3).  A significant reduction in these  levels is
needed in order to meet air quality  standards.

        Sulfur dioxide levels were below ambient air quality standards (Table
A-4) and the data indicate that there  is a tolerance for an increase in the
1973 levels, and still maintain air  quality standards.  All of the  S0? mon-
itoring sites are located outside of the West Virginia portion of this AQCR,
and of these stations, less than half  had sufficient data with which to
calculate an annual arithmetic mean.

3.1.2  Power Plant Assessment
       There is one West Virginia power plant in this AQCR, the Sporn plant
in Mason County.  Modeling results for this plant indicate  that with the  pro-
jected 1975 fuel use, the sulfur content can remain near the same as that
used in 1973 (Table C-l), whereas the  SIP allows a slight increase  in the
content.  This plant contributes less  than half of the particulate  emissions
but a large percentage of the sulfur dioxide emissions in the West Virginia
portion of the AQCR.

3.1.3 ' Industrial Source Assessment
       As shown in Table D-l, there  are three major fuel combustion sources
that are emitting over 100 tons per  year of particulates and sulfur dioxide.
Of the total emissions of these pollutants, point sources account for only
a slight percentage of the total.

3.1.4  Area Source Assessment
       Fuel use for area sources is  presented in Table E-l.  Area source
fuel combustion in the West Virginia portion of this AQCR accounts  for approx-
imately one percent of the total particulate and sulfur dioxide emissions.
                                  16

-------
3.1.5  Fuel Use Assessment
       Total fuel use by the region is presented in Appendix E.

3.2  AIR QUALITY CONTROL REGION #113, CUMBERLAND-KEYSER (MARYLAND)
3.2.1  Regional Air Quality Assessment
       Ambient air levels of suspended particulate matter exceeded both the
annual and 24-hour secondary standard during 1973 (Table A-3) in this AQCR.
However, all six of the monitoring stations for this pollutant are located
in the Maryland portion of the AQCR.

       Sulfur dioxide levels were below the standard in this region,  during
1973 and the data indicate a tolerance for an increase  in  the ambient levels
(Table A-4).  As with particulate monitoring, all  of the S02 monitoring sites
are located in Maryland.

3.2.2  Power Plant Assessment
       There is one power plant in the West Virginia portion of  this  AQCR,
the Mount Storm plant in Grant County.  This plant accounts  for  a large per-
centage of the particulate and sulfur dioxide emissions in the West Virginia
portion of this AQCR.  Modeling results show that in 1975  the sulfur  content
can be increased slightly from that used in 1973,  although the SIP requires
a slight reduction (Table C-l).  This plant was involved in  some controversy
during the late 1960's when the emissions from the plant were thought to be
damaging some Christmas trees nearby in Maryland.   The  Virginia  Electric and
Power Company made an out-of-court settlement for the damages.   In light of
this situation, sulfur dioxide data need to be evaluated in  more detail, before
any consideration is given to relaxing emission standards.

3.2.3  Industrial. Commercial, Institutional Source Assessment
       There are no major fuel combustion point sources in the West Virginia
portion of this AQCR.

3.2.4  Area Source Assessment
       Area source fuel combustion contributes less than ten percent  of the
                                   11

-------
 particulate emissions  and  a negligible amount of the sulfur dioxide emissions
 in  the West Virginia portion of this AQCR.  Fuel use by area sources is pre-
 sented in Table E-l.

 3.2.5  Fuel Use Assessment
       Total  fuel use  data by the region are presented in Appendix E.

3.3  AIR QUALITY CONTROL REGION #179, PARKERSBURG - MARIETTA (OHIO)
3.3.1  Regional Air Quality Assessment
       There were insufficient air monitoring data for suspended particulates
collected in this region to determine an annual  geometric mean for 1973, how-
ever, the second highest 24-hour value of 151  pg/m3 barely exceeded the secon-
dary standard of 150 yg/m3.  A minimal reduction in the 1973 ambient levels
is required to achieve standards for this pollutant.

       The air quality status of sulfur dioxide  is difficult to assess  since
there are no 1973 data available for either the  24-hour bubbler or continuous
monitor.

3.3.2  Power Plant Assessment
       There is one West Virginia power plant in this  AQCR,  the Willow  Island
plant in Pleasants County.   This plant has  been  burning high sulfur coal,  4.5%
in 1972 and 3.72% in 1973.   Modeling results show that in 1975, the sulfur
content will  have to be reduced to 1.5% which  is also  required by the SIP  to
maintain air quality standards in the vicinity of the  plant (Table C-l).  This
plant contributes a significant amount of both the particulate and sulfur
dioxide emissions in the West Virginia portion of this AQCR.

3.3.3  Industrial  Source Assessment
       There are five major West Virginia fuel  combustion sources in  this
AQCR which are listed in Table D-l.   These  sources contribute approximately
one-third of the particulate and sulfur dioxide  emissions in the West Virginia
portion of the AQCR.
                                   18

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3.3.4  Area Source Assessment
       Area source fuel combustion contributes approximately two percent of
the particulate and sulfur dioxide emissions within the West Virginia portion
of this AQCR.  Fuel use by area sources is shown in Table E-l.

3.3.5  Fuel Use Assessment
       Fuel use data by the region are presented in Appendix E.

3.4  AIR QUALITY CONTROL REGION #181, STEUBENVILLE-WEIRTON-WHEELING (OHIO)
3.4.1   Regional Air Quality Assessment
       Ambient levels of total suspended particulates in this AQCR exceeded
both the annual and 24-hour secondary standards in  1973.  Of the thirty-six
monitoring stations in this region, sixteen stations exceeded the annual
standard, and twenty-six stations exceeded the 24-hour standard.   There were
insufficient data in the West Virginia portion of the AQCR to calculate an
annual geometric mean, however, the secondary 24-hour standard  was exceeded
at five of the twelve West Virginia monitoring sites.  A significant reduction
in 1973 ambient levels is required at attain air quality standards in this
region (Table A-3).

        Ambient levels of sulfur dioxide in this region exceeded both the
annual and 24-hour standard during 1973, and occurred in the Ohio portion of
the AQCR.  A significant reduction in the 1973 ambient air levels, with a
corresponding reduction in SO^ emissions is needed  to meet air  quality
standards.  (Table A-4)

3.4.2   Power Plant Assessment
       There were three power plants operating in the West Virginia portion
of this AQCR during 1973, all  of which have been using high  sulfur content
coal.   (Table C-l).  The Windsor plant in Brooke-County burned  3.68%
sulfur coal in 1972 and 3.44% in 1973, and has since ceased  operations.
There  are two power plants in Marshall County, the  Kammer and Mitchell Plants.
The Kammer plant which used 4.03% sulfur coal in 1973 can burn  4.0% coal  in
1975 according to modeling results, whereas the SIP requires 1.7% to maintain
                                   19

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air quality standards in the vicinity of the plant.  The Mitchell plant burned
3.37% sulfur coal during 1973, slightly less than the 3.691 allowed by modeling
results, however the SIP requires 1.6% sulfur coal at this plant.  Electricity
generation accounts for approximately one-third of the particulate emissions,
and over three-fourths of the sulfur dioxide emissions in the West Virginia
portion of this AQCR.

3.4.3  Industrial Source Assessment
       There are several major West Virginia fuel combustion  sources in this
region which are listed in Table D-l.  This is a highly industrialized region
in which point source fuel combustion accounts for approximately 111,000 tons
per year of particulate emissions and 123,000 tons of sulfur dioxide emissions.

3.4.4  Area Source Assessment
       Area source fuel combustion accounts for approximately one percent of
the particulate and sulfur dioxide emissions in the West Virginia portion of
this AQCR.  Fuel use by area sources is shown in Table E-l.

3.4.5  Fuel Use Assessment
       Fuel use by the region is presented in Appendix E.

3.5  AIR QUALITY CONTROL REGION #231, ALLEGHENY
3.5.1  Regional Air Quality Assessment
       There were no monitoring data for either suspended particulates or
sulfur dioxide in this AQCR for 1973.  This is a Priority III region for both
of these pollutants, and as previously mentioned, air monitors were not re-
quired during 1973.

3.5.2  Power Plant Assessment
       There are no power plants in this Air Quality Control  Region.

3.5.3  Industrial Source Assessment
       There is one major fuel combustion source in this region which is
listed in Table D-l.  The emissions from this source are not  significant in
                                   20

-------
comparison to the regional  total  as it accounts  for approximately one  percent
of the participate emissions, and six percent of the sulfur dioxide  emissions.

3.5.4  Area Source Assessment
       Area source fuel  combustion accounts for  only one percent of  the  par-
ticulate emissions, but a significant amount of  the sulfur dioxide emissions
in this region.  Total fuel use for area sources is shown in Table E-l.  There
are almost 100,000 tons of bituminous coal  containing 2.0% sulfur and  10% ash
being burned in this region by residential  sources only.  Over 90% of the
distillate oil burned in this region is by residential sources, however in
most cases it is impractical for these sources to switch to coal if  they
were allowed to do so.  A substantial percentage of natural gas used in
this area is burned by industrial and commercial sources thereby affording
some possibility of saving this fuel if fuel switching is allowed under
revised regulations.  However, it does not seem feasible to relax emission
regulations for area sources only.

3.5.5  Fuel Use Assessment
       Fuel use by the region is shown in Appendix E.

3.6  AIR QUALITY CONTROL REGION #232, CENTRAL WEST VIRGINIA
3.6.1  Regional Air Quality
       There were no air monitoring sites for either suspended particulates
or sulfur dioxide in this AQCR during 1973 as shown in Tables A-3 and  A-4.
Again this is a Priority III region for these pollutants, and air monitors
were not required during 1973.

3.6.2  Power Plant Assessment
       There are no power plants in this Air Quality Control Region.

3.6.3  Industrial, Commercial, Institutional Source Assessment
       There are no major fuel combustion point  sources in this Air  Quality
Control Region.

-------
3.6.4  Area Source Assessment
       Area source fuel combustion contributes approximately three percent
of the particulate emissions, and seventeen percent of the sulfur dioxide
emissions in this region.  Total fuel use by area sources is shown in Table
E-l.   All of the coal used in this region was by residential sources only.
The predominant fuel  used in this region by industrial and commercial sources
is natural gas as over 60% of this fuel is consumed by these sources.  If
regulations are revised, allowing a fuel switch, there is a possibility of
saving a significant amount of this fuel if changes in fuel burning equip-
ment are economically feasible by these sources.  Approximately 55,000
barrels of distillate oil containing 0.3% sulfur are burned in this region,
however it is usually impractical for these sources to change to coal al-
though a switch to higher sulfur oil may be possible.  Again, relaxation of
emission regulations for area sources only, does not seem feasible.

3.6.5  Fuel Use Assessment
       Fuel use by the Region is shown in Appendix E.

3.7  AIR QUALITY CONTROL REGION #233, EASTERN PANHANDLE
3.7.1  Regional Air Quality Assessment
       As with the previous two air quality control regions, there are no
monitoring sites for either suspended particulates or sulfur dioxide located
in this region.  The region is classified Priority III for these pollutants
and air monitors were not required during 1973.

3.7.2  Power Plant Assessment
       There are no power plants in this Air Quality Control Region.

3.7.3  Industrial, Commercial, Institutional Source Assessment
       There are no major fuel combustion point sources in this Air Quality
Control Region.

3.7.4  Area Source Assessment
       Area source fuel combustion accounts for only a slight amount of the
                                 22

-------
particulate emissions but a large percentage of the S02 emissions in this
region.  Total fuel use by area sources is shown in Table E-l.  Residential
sources account for all of the bituminous coal and 94% of the distillate oil
used in this region.  A switch from oil to coal by these sources is usually
impractical because of economic considerations, however, a higher sulfur con-
tent distillate oil could be used if regulations were relaxed.  Approximately
77% of the natural gas used in this region is by industrial sources, thereby
creating a potential for saving this fuel if fuel switching was practical.

3.7.5  Fuel Use Assessment
       Fuel use by the Region is shown in Appendix E.

3.8  AIR QUALITY CONTROL REGION #234, KANAWHA VALLEY
3.8.1  Regional Air Quality Assessment
       Ambient levels of total suspended particulate exceeded both the annual
and 24-hour primary and secondary standard during 1973.  The annual standard
was exceeded at two of the thirteen monitoring stations, and the 24-hour
standard was exceeded at six stations (Table A-3).  A significant reduction
in the 1973 levels is needed to meet air quality standards.

       Ambient air levels of sulfur dioxide were not in violation of the 24-
hour standards during 1973 and the data shows that there is a tolerance for
a significant increase in ambient levels and still maintain air quality stand-
ards (Table A-4).   However, in the past, this region has had high sulfur dioxide
levels, and further analysis of sulfur dioxide data is needed.

3.8.2  Power Plant Assessment
       There are three power plants in this region, all of them located in
Kanawha County.  The Cabin Creek and Amos plants burned coal containing a
higher sulfur content than allowed by the SIP, while at the Kanawha River
plant the coal sulfur content was slightly below SIP requirements.  There
are no modeling data available to determine the allowable sulfur content
of the fuel that may be used at these plants.  The total sulfur dioxide emis-
sions from these three plants during 1973 amounted to approximately 222,000 tons.
                                     23

-------
3.8.3  Industrial Source Assessment
       There are several major fuel combustion sources in this region which
are listed in Table D-1.  Point source fuel combustion accounts for approxi-
mately 93,000 tons of particulate emissions and 84,000 tons of sulfur dioxide
emissions per year.

3.8.4  Area Source Assessment
       Area source fuel combustion accounts for less than one percent of the
particulate and sulfur dioxide emissions in this region.   There is a substantial
amount of natural gas used in this region and almost 60%  of it is  used by in-
dustrial and commercial sources.   Residential sources account for  all of the
coal use, and approximately one third of the distillate oil and natural  gas
use.  Total fuel use by area sources are shown in Table E-l.

3.8.5  Fuel Use Assessment
       Fuel use data are presented in Appendix E.

3.9  AIR QUALITY CONTROL REGION #235, NORTH CENTRAL WEST  VIRGINIA
3.9.1  Regional Air Quality Assessment
       Ambient levels of particulate matter met the 24-hour secondary standard
for particulate matter during 1973, however, there were insufficient data to
determine an annual mean.   The second highest reading of  139 yg/m^ for a 24-
hour average permits a slight increase in the ambient levels  and still  main-
tain air quality standards.

       There are no sulfur dioxide air quality data available for  this AQCR,
as air monitors were not required during 1973 since this  is a Priority III
region for sulfur dioxide.

3.9.2  Power Plant Assessment
       There are three power plants in this AQCR which contribute  approximately
one half of the particulate emissions, and over ninety percent of  the sulfur
dioxide emissions in the region.   The Albright plant in Preston County burned
                                     24

-------
2.02% sulfur coal during 1973, slightly higher than the 1.77% required by
the SIP in 1975.  Modeling results indicate the allowable sulfur content to
be 1.89% for this plant.  The Fort Martin plant burned 2.47% sulfur coal
during 1973, while the SIP requires 2.09% in 1975.  The Rivesville plant
in Marion County must make a significant reduction in sulfur content in order
to comply with the SIP in 1975.   This plant burned 3.47% sulfur coal during
1973, while only 1.99% is allowed by the SIP.   Modeling analysis indicates
that a reduction to 2.09% is required .

3.9.3  Industrial Source Assessment
       There is one major fuel combustion source in this region which is
listed in Table D-l.  The emissions from this  plant are not significant com-
pared to the total as it accounts for less than one percent of the particulate
and sulfur dioxide emissions for the region.

3.9.4  Area Source Assessment
       Area source fuel combustion accounts for only a small percentage of
the particulate and sulfur dioxide emissions in this region.

3.9.5  Fuel Use Assessment
       Fuel use by this region is presented in Appendix  E.

3.10  AIR QUALITY CONTROL REGION #236 - SOUTHERN WEST VIRGINIA
3.10.1  Regional Air Quality Assessment
        Total suspended particulate levels exceeded the 24-hour secondary
standard during 1973.  There were insufficient data available to determine
an annual mean for this region which is classified Priority III for this
pollutant as well as for sulfur dioxide.   There are no sulfur dioxide data
available for this region as air monitors were not required during 1973.

3.10.2  Power Plant Assessment
        There are no power plants in this region.

3.10.3  Industrial, Commercial,  Institutional  Source Assessment
        There are no major fuel  combustion point sources in  this region.

                                    25

-------
3.10.4  Area Source Assessment
        Area source fuel combustion accounts for an estimated seventy per-
cent of the particulate emissions and twelve percent of the sulfur dioxide
emissions in this region.  Residential sources account for all of the coal
used in this region.  There is a considerable amount of natural gas used
in this region by area sources, however, it is usually impractical for these
sources to switch fuels, thereby affording little potential for conserving
this fuel.

3.10.5  Fuel Use Assessment
        Fuel use by the region is shown in Appendix E.
                                    26

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no
                                                        APPENDIX A
                                            STATE  IMPLEMENTATION PLAN BACKGROUND
                                   TABLE A-l.   West Virginia Air  Pollution  Control  Areas
                                                                        Priority
           Air Qua! i ty
          Control  Region
Huntington - Ashland - Portsmouth
Iron ton (Ky.  Ohio)
Cumberland - Keyser (Md.)
Parkersburg - Marietta (Ohio)
Steubenville - Weirton
Wheeling (Ohio)
Allegheny
Central West Virginia
Eastern Panhandle
Kanawha Valley
North Central West Virginia
Southern West Virginia
Federal
Number
103
113
179
181
231
232
233
234
235
236
Parti -
culates
I
I
I
I
III
III
III
I
I
III
Classification
SOx
III
I
II
I
III
III
III
III
III
III
N0x
III
III
III
III
III
III
III
III
III
III
Population
1975
(Millions)
0.63
0.23
0.29
0.49
0.17
0.14
0.07
0.28
0.26
0.38
                              Criteria Based on Maximum Measured (or Estimated) Pollution Concentration in Area
Priority

Sulfur oxide:
Annual arithmetic mean
24-hour maximum
Parti culate matter:
Annual geometric mean
24-hour maximum
I II
Greater than
100
455
95
325
From - To
60-100
260-455
60-95
150-325
III
Less than
60
260
60
150

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        Federal
        State
                                                       TABLE  A-2


                                  WEST  VIRGINIA AMBIENT AIR QUALITY  STANDARDS (ug/m3)




                                  Total  Suspended Participate             Sulfur Oxides

                                       Annual     24-llour         Annual       24-Hour    3-Hour
Nitrogen Oxides

    Annual
Primary
Secondary
Primary
Secondary
75
60
75
60
260a
1503
260a
150a
80
—
80
60
3659
—
365a
260a
—
13003
—
13003
TOO
TOO
TOO
—
ro
oo
                       a Not to be exceeded more than  once  per year

-------
                                                                           TABLE A-3
                                                             WEST VIRGINIA AIR QUALITY STATUS, TSPa
                                                     TSP Concentration  (ugm/m^)
Number of Stations Exceeding
Ambient Air Quality Standards


Highest
Reading 2nd Highest Reading
Air Quality No Stations
Control Region Reporting Annual
Hunti ngton-Ashl and-Portsmouth * d
Cumberland-Keyserb> e
Parkersburg-Marietta15
S teubenvi 1 1 e-Wei rton-Wheel i ngb ' d
Allegheny
Central West Virginia
Eastern Panhandle
Kanawha Valley
North Central West Virginia
Southern West Virginia
40
6
3
36
0
0
0
13
5
2
96
85
- _
187
--
--
--
102
---
—
24-Hr
349
423
268
621
«
--
--
501
186
326
24 Hr
239
185
151
574
—
—
-.
318
139
319
Primary
Annual
5
2
.
15
	
	
__
2
-
-
24-Hrc
0
0
0
n
__
._
	
2
0
1
Annual
13
5

16
	
--.
__
2
_
_
Secondary
%
33
83

44
-_
..
._
15
—
__
24-HrC
12
4
1
26
..
_.
..
6
0
2
%Reduction Required
to
%
33
66
33
72
..


46
0
100
Meet Standards*

+ 53
+ 44
+ 1
+ 80



+ 58
- 9
+ 58
a 1973 Air Quality in National  Air Data Bank,  July 28, 1974
b Interstate
c Violations based on more than one reading in excess of standard
d Highest and second highest reading recorded  in Ohio portion  of AQCR
e No monitoring stations in W.  Va. portion of  AQCR
f Formula:
              (2nd Highest 24 Hr - 24 Hr Secondary Standard)   x 100,   (Annual  -  Annual  Secondary  Standard)  x  100
                       2nd Highest 24-Hr - Background                         Annual  -  Background
Background:  28 pg/ir|3

-------
                                                                          TABLE A-4
                                                            WEST VIRGINIA AIR QUALITY STATUS, S0xa

                                                                       S00  Concentration  (ugm/m3)
                                                                                                            Number of Stations  Exceeding
                                                                                                            Ambient Air Quality Standards
OJ
o

Air Quality No. Stations
Control Region 24 Hr
Huntington-Ashland-Portsmoutb^' d
Cumber 1 and- Keyser&» d
Parkersburg-Marietta6
Steubenville-Weirton-Wheelingb> e '
Allegheny
Central West Virginia
Eastern Panhandle
Kanawha Valley
North Central West Virginia
Southern West Virginia
17
6
0
16
0
0
0
8
0
0

Reporting
Cont.
1
2
0
1
-
0
0
0
-
0
Highest
Annual
28
28
—
106
—
—
—
399
—
--
Reading 2nd Highest Reading Primary
24-Hr
429
562
...
432
...
.__
---
228

— -
24-Hr
178
10.1
...
403
—
___
...
149
„_
—
Annual %
0 0
0 0
-
1 6
-
-
-
-
-
-
Secondary
% Reduction Required
to Meet Standards'^
24-Hrc % 3-Hrc
0
0
-
4
-
-
-
0
-
-
0 0
0 0
-
25
-
-
-
0
-
-
- 105
- 186
-
+ 25
-
-
-
- 105
-
-
a 1973 Air Quality Data in National  Air Data Bank,  July  28,  1974
b Interstate
c Violations based on more than one  reading in  excess  of standard
^ No monitoring stations located in  West Virginia
e Highest and second highest readings  recorded  in Ohio portion of AQCR
^ Formula:
                (2nd Highest 24 Hr - 24 Hr Secondary Standard)  x   100,
                         2nd Highest 24-Hr - Background
9 From Fiscal  Year 1973 Annual  Report.,  West  Virginia Air Pollution Control Commission
                                                                        (Annual - Annual Secondary Standard)  x
                                                                                Annual - Background
100

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                                                                 TABLE A-5
                                                WEST  VIRGINIA  FUEL COMBUSTION SOURCE SUMMARY
Air Quality
Control Region
Huntington-Ashland-Portsmouth-
Ironton6
Cumberland-Keyser6
Parkersburg-Marietta6
Steubenville-Weirton-Wheeling6
Allegheny
Central West Virginia
Eastern Panhandle
Kanawha Valley
North Central West Virginia
Southern West Virginia
TOTAL
Power
Plants3
1

1
1
2
0
0
0
3
3
0
11
Other Fuel Combustion j
Plant Sources^ „„„,

TSP
3

0
5
7
1
0
0
7
1
0
24

SO g
3

0
5
8
1
0
0
8
1
0
26
	 ni ca
' Sources0
3

2
5
4
11
12
3
3
6
9
58
Total En
(|Q3Ton
TSP
82.5

3.3
38.5
195.0
48.0
15.6
36.1
147.5
121.4
3.3
691.2
iissionsd I
is/Year)
SO?
103.4

168.6
135.4
624.0
4.9
14.4
1.6
331.5
349.8
72.5
1806.1
> West Virginia Emissions From
Fuel Combustion Sources

TSP
48

100
76
89
4
4
1
79
55
70


SO?
98

99
94
98
96
17
88
92
95
12

  Plants in West Virginia
  Sources emitting 100 tons or more per year of  either  particulates or sulfur dioxide
c West Virginia Counties
d AQCR Total
e Interstate

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                                                               TABLE A-6
                                              WEST  VIRGINIA  PARTICULATE EMISSIONS SUMMARY3
ni r yudi i iy
Control Region
Huntington-Ashland-Portsmouth-
Irontonc
Cumberland-Keyserc
Parkersburg-Mariettac
Steubenville-Weirton-Wheeling0
Allegheny
Central West Virginia
Eastern Panhandle
Kanawha Valley
North Central West Virginia
Southern West Virginia
lULCU tllllbb (Ullb
(103 Tons/Yr)
82.5

3.3d
38.5
195.0
48.0
15.6
36.1
147.5
121.4
3.3e
(IP3 Tons/Yr)
37.0

3.0d
14.3
60.2
0
0
0
23. Of
61.8
0
%
45

91
37
31
--
--
—
16
51
--
(103 Tons/Yr)
1.4

0
14.2
111.5
0.5
0
0
93.3
0.5
0
*
2

-
37
57
1
-
0
63
-
-
(103 Tons/Yr)
0.6

0.3
0.7
1.4
1.5e
0.7e
0.4e
0.7
4.7
2.3e
%
1

9
2
1
3
4
1
-
4
70
Data are from West Virginia SIP Emission Inventory unless  otherwise  noted.   Emissions  for  interstate  regions are for  the West Virginia portion
only.
Includes emissions from all sources
Interstate AQCR
1973 emissions
Data from 1972 National Emissions Report, EPA,  June 1974
1973 emissions from three power plants

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                                                                     TABLE A-7
                                                  WEST VIRGINIA SULFUR DIOXIDE EMISSIONS SUMMARY6
         Air Quality
        Control Region
Hunti ngton-Ashland-Portsmouth
  Irontonc
Cumber!and-Keyserc
Parkersburg-Marietta
Steubenvi11e-Wei rton-Wheeli ngc
Allegheny
Central West Virginia
Eastern Panhandle
Kanawha Valley
North Central West Virginia
Southern West Virginia
Total  Emissions0
 (103  Tons/Yr)

     103.4
     168.6
     135.4
     624.0
       4.9d ,
      14.4
       1.6
     331.5
     349.8
      72.5
                                                          Electricity Generation
Point Source Fuel  Combustion
Area Source Fuel Combustion
(TO3 Tons/Yr) %
98.7
166.6
85.9
478.2
0
0
0
222.06
329.0
0
95
99
63
77
--
--
--
67
94
_.
(103 Tons/Yr) %
2.5
0
37.4
123.7
0.3
0
0
84.3
0.6
0
2
--
28
20
6
--
--
25
—
—
(103 Tons/Yr)
1.0d
0.5
3.2
5.9
4.4d
2.4d
1.4d
1.4
3.7d
8.4
%
1
--
2
1
90
17
88
--
1
12
  Data are from West Virginia SIP Emission Inventory unless otherwise noted.   Emissions for interstate regions  are for  the  West Virginia portion only.
  Includes emissions from all sources
  Interstate AQCR
  Data from 1972 National Emissions Report, EPA, June 1974
  1973 emissions from three power plants

-------
       Air Quality
      Control  Region
Huntington-Ashland-Portsmouth
Cumberland-Keyser
Parkersburg-Marietta
Steubenvi1le-Weirton-Wheeli ng
Allegheny
Central West Virginia
Eastern Panhandle
Kanawha Valley
North Central West Virginia
Southern West Virginia
                TABLE A-8
WEST VIRGINIA AQCR REQUIRED EMISSION REDUCTION6

     Required Particulate Emission Reduction
                      103 tons/year
+53
+44
+ 1
+80
N.D.
N.D.
N.D.
+58
- 9
+58
+44.0
+ 1.5
+ 0.4
+156.0
N.D.
N.D.
N.D.
+85.6
-10.9
+ 1.9
Required SO- Emission Reduction
              IP3 tons/year
-105
-186
N.D.
+ 25
N.D.
N.D.
N.D.
-105
N.D.
N.D.
-108.6
-313.6
N.D.
+ 156
N.D.
n.D.
N.D.
-348.1
N.D.
N.D.
a
  Based on a proportional change of emissions to air quality (1973)
  Interstate
N.D. - No air quality data.

-------
                               TABLE A-9
             SUMMARY  OF  FUEL  COMBUSTION  EMISSION  REGULATIONS

 I.   PARTICULATE  MATTER  (lbs/106BTU)
     a.   Electric power  plants
         Total  design heat input  (106BTU/Hr)  x  0.05  not  to exceed  1200  Ibs/Hr.
     b.   Industrial fuel  fired  furnaces, cyclone  furnaces, gas-fired, and
         liquid-fuel-fired units.
         Total  design heat input  (106BTU/Hr)  x  0.09  not  to exceed  900 Ibs/Hr.

II.   SULFUR OXIDES  (lbs/106BTU)
     A.   West Virginia priority I  and priority  II  regions
     1.   Electric power  plants
         a.  By June  30,  1975
             Total  design heat  input  (106BTU/Hr)  x 2.7
         b.  By June  30,  1978
             Total  design heat  input  (106BTU/Hr)  x 2.0 not to exceed 45,000  Ibs/Hr.
     2.   All other fuel  combustion units
         a.  By June  30,  1975
             Total  design heat  input  (106BTU/Hr)  x 3.1
         b.  By June  30,  1978
             Total  design heat  input  (106BTU/Hr)  x 2.3 Not to exceed 8,000 Ibs/Hr.
     B.   Region IV, Kanawha Valley Air Quality  Control Region -  Effective
         January  1, 1973
     1.   Electric power  Plants
         Total  design heat input  (106BTU/Hr)  x  1.6 not to exceed 45,000 Ibs/Hr.
     2.   All other fuel  combustion units
         Total  design heat input  (106BTU/Hr)  x  1.6 not to exceed 5,500  Ibs/Hr.
     C.   All other priority III Regions
     1.   Electric power  plants  and all other  units
         Total  design heat input  (106BTU/Hr)  x  3'.2
                                  35

-------
                                                                            APPENDIX  B
                                                                        REGIONAL ASSESSMENT

                                                                              TABLE  B-l
                                                            REGIONAL INDICATORS  FOR  REVISION  OF  TSP  REGULATIONS
Air Quality
Control Region
Huntington-Ashland-Portsmouth
Cumberl and-Keyser
Parkersburg-Mari etta
S teubenvi 1 le-Wei rton-Wheel i ng
Allegheny
Central West Virginia
Eastern Panhandle
Kanawha Valley
North Central West Virginia
Southern West Virginia
Air Quality
# # Of Stations
Stations In Violation
103 c
113
179
181
231
232
233
234
235
236
40
6
3
36
0
0
0
13
5
2
12
5
1
26
-
-
-
6
0
2
Expected
Attainment
Date
6/75a
6/75a
6/75a
6/75a
b
b
b
6/753
6/75a
b
TSP % Emissions
Emissions From W. Va.
(103 Tons/Yr) Fuel Combustion
82.5
3.3
38.5
195.0
48.0
15.6
36.1
147.5
121.4
.. 3.3
48
100
76
89
4
. 4
1
79
55
70
Emission Reduction
Req'd for NAAQS
(103 Tons/Yr)
+ 44.0
+ 1.5
+ 0.4
+156.0
N.D.
N.D.
N.D.
+ 85.6
- 10.9
+ 1.9
TSP
Priority
I
I
I
I
III
III
III
I
I
III
a.  Attainment date is for Primary Standard.  Attainment date for Secondary Standard is 6/77
b.  Air Quality below standard at time of classification.
N.D. No air quality data available.

-------
                                                                                 TABLE B-2
                                                            REGIONAL INDICATORS FOR REVISION OF S02 REGULATIONS
Air Quality
Control Region
Huntington-Ashland-Portsmouth
Cumber! and- Keyser
Parkersburg-Marietta
Steubenvi 1 1 e-Weirton-Wheel i ng
Allegheny
Central West Virginia
Eastern Panhandle
Kanawha Valley
North Central West Virginia
Southern West Virginia
103
113
179
181
231
232
233
234
235
236
Air
#
Stations
18
8
0 ,
17
0
0
0
8
0
0
Quality
# Of Stations
In Violation
0
0
-
5
-
-
-
0
0
0
Expected
Attainment
Date
b
6/75a
6/75a
6/75a
b
b
b
b
b
b
so2
Emissions
(103 Tons/Yr)
103.4
168.6
135.4
624.0
4.9
14.4
1.6
331.5
349.8
72.5
% Emissions
From W. Va.
Fuel Combustion
98
99
94
98
96
17
88
92.
95
12
Emission Reduction
Req'd for NAAQS
(10-3 Tons/Yr)
-108.6
-313.6
N.D.
+ 156
N.D.
N.D.
N.D.
-348.1
N.D.
N.D.
so2
Priority
III
I
II.
I
III
III
III
III
III
III
a.  Attainment date is for Primary Standard.   Attainment date for Secondary Standard  is  6/78
b.  Air Quality levels below standard at time of classification.
N.D.  No data av&ju/ data available.

-------
 Air Quality Control Region
Huntington-Ashland-
 Portsmouth-Ironton
Cumber!and-Keyser
Parkersburg-Marietta
Steubenvi11e-Weirton-Wheel i ng
Kanawha Valley
North Central West Virginia
                                                      APPENDIX  C
                                                POWER PLANT ASSESSMENT
                                                       TABLE C-l
                                         WEST VIRGINIA POWER PLANT ASSESSMENT*
Plant
Sporn
Mount Storm
Willow Island
Windsor
Kammer
Mitchell
Cabin Creek
Kanawha River
Amos

Albright
Fort Martin
Capacity (MW)
1973
1975
1105.59
1105.59
1695.47
1695.47
215.0
215.0
300.0
300.0
712.5
712.5
1632.6
1632.6
273.5
273.5
439.4
439.4
1632.6
2932.6

278.25
278.25
1152.0
1152.0
Fuel
Type
% Sulfur
Coal
1.34% S
Coal
1 .96% S
Coal
3.72% S
Coal
3.44% S
Coal
4.03% S
Coal
3.37% S
Coal
1.19% S
Coal
0.85% S
Coald
1.13% S
Oild
Coal
2.02% S
Coal
2.47% S
Use 1973
Annual
Quantityb
2341.61
2606.0
605.64
119.83
1510.79
3776.78
339.29
1134.09
3114.8
122.5
771.65
2680.8
Fuel Use
1975
Type
Quantity0
Coal
2805
Coal
4598
Coal
725
Coal
608
Coal
1511
Coal
3266
Coal
292
Coal
1320

Coal
993
Coal
2579
SIP
% S
1.77
1-.6
1.47
1.53
1.6
1.53
0.98
0.88
0.95

1.77
2.09
Modeling'
% S
1.4
2.3
1.5
—
4.0
3.69
—
—

1.89
3.09

-------
TABLE C-l Ccont.)
 Air Quality Control Region
North Central West Virginia
   (cont.)
Plant
Rivesville

Capacity (MW)
1973
1975
174.75
174.75

Fuel Use 1973
Type Annual
% Sulfur Quantity13
Coal 475.0
3.47% S
Fuel Use
1975
Type
Quantity0
Coal
455


SIP
% S
1.99



Modeling
% S
2.09

  Data from Federal Power Commission.
  Coal is in 10^ tons, oil is in 10^ barrels.
c The modeling results presented in this table assumed a 75 yg/m^ contribution from sources other than the power
  plants.  These modeling results should be substantiated with actual air quality measurements and qualified.
d Fuel use is for  1972.

-------
                          ADDENDUM TO APPENDIX C

             USE AND LIMITATIONS OF MODELING ANALYSIS DATA9
     1.  The data inputs for the modeling have been extracted from the
appropriate FPC Form 67 and the most representative meteorological data
available.  However, to calculate the occurrence of the highest 24-hour
concentration, assumptions as to the daily emission rate are necessary.
The results of the modeling exercise provide a range of the most probable
maximum concentration.

     2.  It should be recognized that time and data constraints are such
that the model predictions are useful but not omniscient.   There are no
data available, in general, to "validate" the model.  Therefore, all rele-
vant data, including hard data on actual daily plant operations, should
be obtained, reviewed, and evaluated.  In this way, the modeling results
can be used as a logical part of the entire decision-making framework, not
as an arbitrary, dogmatic absolute "answer", divorced from the real situation
involved.  In some cases it will be necessary to adjust the model's predic-
tions based upon more complete and detailed information on a particular
plant's operations.

     3.  Results of these evaluations are not intended to be used in any
legal actions, including both public hearing and court proceedings.  The
very nature of atmospheric dispersion modeling is such that results are not
suitable to legally prove (or disprove) a particular modeling result.   The
assumptions and judgments necessarily involved in modeling tend to mitigate
against proof in a legal sense.

     4.  The best use of the data is in negotiations with  states or sources
in trying to establish a rational course of action to be followed with reason-
able assurance that the air quality impact will be as indicated by the model.
a Extracted from comments by the Monitoring and Data Analysis  Division,  OAQPS
                                    41

-------
        Air Quality
       Control Region
                                        APPENDIX  D
                         INDUSTRIAL FUEL COMBUSTION SOURCE LISTING
                                         TABLE D-l
                         MAJOR INDUSTRIAL FUEL COMBUSTION SOURCES3
             Source
Huntington-Ashland-Portsmouth-
  Ironton
Parkersburg-Marietta
Steubenville-Weirton-Wheeling
Allegheny

Kanawha Valley
                                                                           Emission (Tons/Yr)
Chemetron Corp.
C & 0 Railway
Novamont Corp.

E. I. DuPont
Union Carbide
American Cyanamid
FMC Corp.
Quaker State Oil

PPG
Weirton Steel
Allied Chemical
Wheeling Pittsburg Steel (Follansbee)
Koppers
Triangle Conduit & Cable
Wheeling Pittsburg Steel (Benwood)
Banner Fibreboard

B & 0 Railroad

Union Carbide (Institute)
Part.
741
308
270
969
861
3209
8524
664
44375
51056
804
5944
2274
546
913
3
406
9150
SOy
861
744
739
11725
9361
6830
6710
2733
55957
42260b
12784
4910C
3523
1623
1258
145
260
20334

-------
TABLE D-l (cont.)
        Air Quality
       Control Region
Kanawha Valley (cont.)
                                                                           Emission (Tons/Yr)
Source
Union Carbide (South Charleston)
E. I. DuPont
FMC (South Charleston)
Union Carbide (Alley)
FMC-Viscose (NITRO)
Monsanto
Union Carbide (Tech. Center)
Part.
9921
1843
4426
49921
17040
840
96
sox
15942
13369
13013
12514
4141
4131
897
North Central West Virginia
B & 0 Railroad
546
564
  Sources emitting 100 tons or more per year of either particulates or sulfur oxides.  Data are ..
  from SIP Emission Inventory.  Sources are listed in decreasing order of SOX emissions.
  Includes 1,020 tons from coke oven gas, 2438 tons from fuel oil, and 38802 tons from coal
  combustion.
  Includes 3443 tons from coal, and 1467 tons from coke oven gas combustion

-------
                                                       APPENDIX  E
01
Air Quality Control Region

Huntington-Ashland-Portsmouth
Ironton
  Area Sources
  Point Sources
                Total
Cumberland-Keyser
  Area Sources
  Point Sources
                Total
Parkersburg-Mari etta
  Area Sources
  Point Sources
                Total
Steubenvilie-Wei rton
Wheeling
  Area Sources
  Point Sources
                Total
                                                      AQCR FUEL USE
                                                        TABLE  E-l
                                                    FUEL USE  SUMMARY

                                           Coal  (IP3  Tons)
                                                                 Oil  (IP*3 Barrels)
Gas (IP6 cu. ft.)
Anthracite
4
0
4
73
0
73
2
0
2
9
0
9
Bi tumi nous
1 79
8327
1 8506
22
3443
3465
85
5354
5439
273
11970
12243
Residual
121
227
348
354
871
1225
46
0.6
46.6
55
42
97
Distillate
1389
560
1949
938
0.4
938.4
445
0.1
445.1
1141
2
1143
Natural
51320
7391
58711
10750
3452
14202
24680
664
25344
33080
3375
36455
Process
0
9900
9900
0
0
0
0
0
0
0
109865
109865

-------
      TABLE E-l  (Continued)
        FUEL USE SUMMARY
Coal  (10  Tons)
Oil (10  Barrels)
Gas (10° cu. ft.)
Air Quality Control Region
Allegheny
Area Sources
Point Sources
Total
Central West Virginia
Area Sources
Point Sources
Total
Eastern Panhandle
Area Sources
Point Sources
Total
Kanawha Valley
Area Sources
Point Sources
Total
North Central West
Virginia
Area Sources
Point Sources
Total
Anthracite

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0
Bi tuminous

100
0
100

54
0
54

20
0
20

35
1612
1647

81
0
81
Residual

48
0
48

37
0
37

21
0
21

99
0
99

80
0
80
Distillate

365
0
365

85
0
85

330
0
330

117
0
117

140
0
140
Natural

9090
0
9090

11920
0
11920

4490
0
4490

29530
0
29530

23090
0
23090
Process

0
0
0

0
0
0

0
0
0

0
0
0

0
0
0

-------
                                          TABLE E-l (Continued)
                                            FUEL USE SUMMARY
Air Quality Control Region
Southern West Virginia
  Area Sources
  Point Sources
      Total
                                    Coal (10  Tons)
Oil (10  Barrels)
Gas (10° cu. ft.)
Anthracite
0
0
0
Bi tuminous
197
0
197
Residual
109
0
109
Distillate
172
0
172
Natural
15000
0
15000
Process
0
0
0
a.  Source:  Stationary Source Fuel Summary Report, NEDS, October, 1974

-------
                                   TECHNICAL REPORT DATA
                            (Please read luatnictions on the reverse before completing}
 1. REPORT NO.
  EPA-450/3-75-02Q
                              2.
                                                            3. RECIPIENT'S ACCESSIOWNO.
4. TITLE AND SUBTITLE
  IMPLEMENTATION PLAN  REVIEW  FOR WEST VIRGINIA AS
  REQUIRED BY THE ENERGY  SUPPLY AND ENVIRONMENTAL
  COORDINATION ACT
             5. REPORT DATE
               February 1975
             6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
                                                            8. PERFORMING ORGANIZATION REPORT NO
9. PERFORMING ORGANIZATION NAME AND ADDRESS
                                                            10. PROGRAM ELEMENT NO.
 U.S.  Environmental Protection  Agency, Office of Air
 Quality  Planning and Standards,  Research Triangle
 Park,  N.C.,  Regional Office  III, Philadelphia,
 Pa.,  and TRW,  Inc., Vienna,  Virginia	
              11. CONTRACT/GRANT NO.
                68-02-1385
 12. SPONSORING AGENCY NAME AND ADDRESS
  U.S.  Environmental  Protection Agency
  Office of Air and Waste Management
  Office of Air Quality  Planning and Standards
  Research Triangle Park, North Carolina  27711
              13. TYPE OF REPORT AND PERIOD COVERED
                  Final	
              14. SPONSORING AGENCY CODE
 15. SUPPLEMENTARY NOTES
 16. ABSTRACT
       Section  IV of the Energy  Supply and Environmental  Coordination Act of  1974,
 (ESECA)  requires EPA to review  each  State Implementation Plan (SIP) to determine
 if revisions  can be made to control  regulations for stationary fuel combustion
 sources  without interfering with  the attainment and maintenance of the national
 ambient  air quality standards.   This  document, which is  also required by Section
 IV of ESECA,  is EPA's report to the  State indicating where  regulations might be
 revised.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS  C. COSATI h'leld/Group
  Air pollution
  State Implementation Plans
13. DISTRIBUTION STATEMENT


 Release unlimited
19. SECURITY CLASS (This Report/

  Unc.lassified	
                                                                         21. NO. OF PAGES
53
20. SECURITY CLASS (Thi

  Unclassified
                           22. PRICE
EPA Form 2220-1 (9-73)
                                            48

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