1 

# Attachment C Oregon State Implementation Plan Revision Addressing the Interstate Transport of Nitrogen Dioxide (NO 2 

# ), Sulfur Dioxide (SO 2 

# ), Lead (Pb) and Fine Particulate Matter (PM 2.5)

Clean Air Act Section 110(a)(2)(D) May 12, 2015

Air Quality Planning

811 SW 6th Avenue
Portland, OR 97204

Phone: (503) 229

- 5696

(800) 452

- 4011

Fax: (503) 229

- 6762 Contact: Nancy Cardwell

503

- 229

- 6610 Nancy Cardwell www.oregon.gov/DEQ

DEQ is a leader in restoring, maintaining and enhancing the quality of Oregon’s air,

land and water.2 

## Contents

Addressing Interstate Pollutant Impacts under the Clean Air Act

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

I. Introduction

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

II. Background

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

III. Air Quality Data and Attainment Status within the State and Surrounding

States

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

IV. Nature of Pollutant Transport

................................ ................................ ................ 2 7

V. Sources of Pollutant Emissions near the State Boundary and Expected

Impacts in Neighboring States

................................ ................................ ........ 2 9

VI. Conclusion

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

C ontact:

Nancy Cardwell Air Planning (503) 229

- 66103 

### Addressing Interstate Pollutant Impacts under the Clean Air Act

Overview

Some amount of air pollution routinely moves across all state borders and across all regions of the country. This

document addresses the effect of Oregon air emissions transporting to neighboring states. Based on the
information summarized in the sections that follow, the Oregon Department of Environmental Quality

concludes that air emissions of nitrogen dioxide ( NO 2 ) , sulfur dioxide ( SO 2 )

, lead (Pb), and fine particulate
matter ( PM 2.5 ) from Oregon sources do not significant ly contribute to violations of N ational A mbient A ir
Q uality S tandards in other states, or interfere with other states ’ efforts to meet air quality standards, prevent ion

of significant deterioration (PSD) , or protect visibility. DEQ’s conclusions are based on its understanding of air pollution problems in adj acent states, and the emission sources, meteorology (weather patterns), and topographic features (mountain ranges, etc.) that influence air quality problems in these states.

DEQ will collaborate with air agencies in Washington, Idaho, Nevada, California a nd other state s whenever necessary to evaluate case

- specific air quality problems that may involve regional movement of air pollution. DEQ’s Clean Air Act s ection 110 infrastructure SIP provides the framework and legal mechanism for DEQ to

act as needed to reduce any Oregon emissions found to significantly contribute to air quality problems in other

states.

The map below (Figure 1) illustrates the significant distances and mountain ranges that in many areas separate Oregon from communities in Washington, C alifornia, Idaho, and Nevada and can help limit the long range transport of air pollution.



### Figure 1: Map of Oregon and major mountain ranges4 I. I ntroduction

The interstate transport provision in the CAA section 110(a)(2)(D)(i) (also called “ the good neighbor” provision) requires each state to submit a State Implementation Plan (SIP) that prohibits emissions that will have certain adverse air quality effects in other states. This SIP submittal is due within three years after the

E nvironmental P rotection A gency adopts a new or revised NAAQS.

II. Background

EPA Promulgated NAAQS

 Nitrogen Dioxide (NO 2 ) : EPA first set standards for NO 2 in 1971 ; setting both a primary standard (to protect health) and a secondary standard (to protect the public welfare) at 53 parts per billion ( ppb ) , averaged annually. EPA reviewed the standards in 1985 and 1996, deciding to retain the

standards at the conclusion of each review. In 2005, EPA began another review, resulting in the January 22, 2010, rulemaking to establish an additional primary NO 2 standard at 100 ppb, averaged over one hour (75 FR 6474).

 Sulfur Dioxide (SO 2 ) : Primary standards for SO 2 were firs t set in 1971, at 0.14 parts per million (ppm) averaged over a 24

- hour period, not to be exceeded more than once per year, and 0.030 ppm, annual arithmetic mean. EPA subsequently reviewed the primary standards and determined to retain

them in 1996. More r ecently, on June 2, 2010, EPA adopted a revised primary SO 2 standard at 75 ppb, based on a three

- year average of the annual 99 th percentile of one

- hour daily maximum concentrations (75 FR 35520).

 Lead (Pb) : On October 15, 2008, the EPA revised the leve l of the primary and secondary Pb NAAQS from 1.5 micrograms per cubic meter (μg/m 3 ) to 0.15 μg/m 3

.

 Fine Particulate Matter (PM 2.5 ) : On December 14, 2012 EPA adopted a revised annual NAAQS for fine particulate matter (PM 2.5 ) from 15 μg/m 3 to 12 μg/m 3

.

Section 110(a)(2)(D)(i) of the CAA identifies four distinct requirements related to the impacts of air pollutants transported across state lines. It requires that each SIP for a new or revised NAAQS contain adequate provisions prohibiting any source or other type of emissions activity with in the state from emitt ing air pollutants that may :

1. C ontribute significantly to nonattainment of the applicable NAAQS in any other state ;

2. I nterfere with maintenance of the applicable NAAQS in any other state ;

3. I nterfere with measures required to be incl uded i n the applicable implementation plan for any other state to prevent significant deterioration of air quality ; and

4. I nterfere with measures required to be included in the applicable implementation plan for any other state to protect visibility

.

Section III below addresses elements 1 and 2 above, contributions to nonattainment of applicable NAAQS, and interference with maintenance of applicable NAAQ S . Regarding element 3 above (prevention of significant deterioration), DEQ’s air permitting rules f or industrial sources require analysis for the PSD5

which ensures that air quality impacts fr o m new or modified industrial sources will not cause or contribute to violations of a NAAQS in Oregon or neighboring states, or cause significant visibility impair ment in

federal Class

- I areas. EPA most recently approved revisions to Oregon’s P SD program on December 27, 2011 (76 FR 80747)

. Regarding element 4 above (visibility protection), Oregon ’ s federally approved regional haze plan pr o vides the mechanism for en suring emission reduction s necessary to achi e ve visibility impr ovement in Oregon and in neighboring s t ates. EPA approved the first element of the Oregon Regional

Haze Plan ( SIP ) including the requirements for b est available retrofit technology (BART) (76 F R 38997) on July 5, 2011

. EPA approved the remaining elements of the Oregon Regional Haze SIP on August 22, 2012 (77 FR 50611).

III. Air Quality D ata and A ttainment S tatus within Oregon and S urrounding States

a. S urrounding c ontiguous s tates : Oregon is bordered by Washington to the north, the Pacific Ocean to the west, California and Nevada to the south, and Idaho to the east. The Snake River separates the state from part of Idaho . The Columbia River forms most of the state's northern border. The re are s ix major sources in Oregon within 5 km of contiguous Washington State and one major source within 5

km of Idaho. The sources are listed in Tables 5 and 6 below (page 29)

.

b. D esignation of all areas within the s tate and in e ach s urrounding s tate (attainment, nonattainment, and unclassifiable) , including maintenance areas in adjacent states :

 Nitrogen Dioxide (NO 2 ) : On January 20, 2012 EPA designated all areas of the country as

“unclassifiable/attainment” for the 2010 NO 2 NAAQS

, including all areas within the states of Idaho, California, Nevada, and Washington . The available air quality data show that all monitored areas in the country meet the 2010 NO 2 NAAQS for 2008

- 2010. No state or tribe recommended an area be designated “nonattainment” d u ring the federal designation process

.

 Sulfur Dioxide (SO 2 ) : According to EPA, designations for the entire state of Oregon, Washington, Idaho, California, and Nevada will be addressed in a future action. See p roposed Consent Decree, Sierra Club v. McCarthy, No. 3:13

- CV

- 3953

- SI (N.D. Cal.), issued March 2, 2014, 70 Fed. Reg. 3 1,325 , June 2, 2014 found at:

https://federalregister.gov/a/2014

- 12693

http://content.sierraclub.org/environmentallaw/sites/content.sierraclub.org.environmentallaw/

files/SO2%20Consent%20D ecree.pdf

EPA's review of the monitored air quality data from 2009

- 2011 showed no violations of 2010 1

- hr SO 2 standard in any of these states. According to the latest available 2013 Oregon Air Quality Data Summaries Report, the downward trend in SO2 emissions continues with the highest 2012

and 2013 1

- hr concentrations under 25 ppb.

 Lead (Pb) : In 2008 EPA designated all areas in the states of O regon, Idaho, Nevada, and Washington as “unclassifiable/attainment

. ” In California, Los Angeles County South Coast Air Basin is classified as “nonattainment.” The rest of the state is designated

“unclassifiable/attainment.”6

 Fine Particulate Matter (PM 2. 5 ) : Shoshone County in Idaho, and Imperial, Fresno, Kings,
Madera, Merced, San Joaquin, Stanislaus, and Tulare counties in California are designated in

nonattainment of the 2012 annual PM2.5 standard. There are no nonattainment areas for the

annual PM 2.5 standard in Oregon, Washington, Idaho, or Nevada. There have been no annual

PM 2.5 NAAQS violations in SW Washington during the most recent three

- year period (2012

- 2014). The m onitoring network for NO2 and SO2 is presented in Figure 2. The m onitoring

n etwork for PM2.5 and Pb is presented in Figure 3.

c. M onitoring n etwork s for p ollutant s within the s tate and s urrounding s tates :



### Figure 2: Monitoring network that includes for NO 2 

### , and SO 2 

### , in Oregon7



### Figure 3: Monitoring network that includes PM 2.5 and Lead in Oregon

Figure 4: Monitoring networks for NO 2 

### in Washington, Idaho,

California and Nevada8



### Figure 5: Monitoring networks for SO 2 

### in Washington, Idaho,

California and Nevada

Figure 6: Monitoring networks for Pb in Washington, Idaho,

California and Nevada9



### Figure 7: Monitoring networks for PM 2.5 in Washington, Idaho,

California and Nevada

d. A mbient data, including the ‘design value’ for pollutant s of interest

, at each monitoring site

and trends over the last 5

- 10 years

.
Nitrogen Dioxide (NO 2 ) :

The level of the hourly NAAQS for NO 2 is 10 0 ppb based on the 98th percentile value from three consecutive years of data. The design values shown here are computed for the latest design value period using Federal Reference Method or equivalent data reported to EPA by States, Tribes, and local agencies

. The 201 1

- 2013 d esign values for NO 2 are presented in Table 1. Daily maximum 1

- hr NO 2

2000

- 2013 trends at monitoring stations in Oregon

, Washin g ton, California , Idaho , and Nevada are in Figures 8

- 11

.

Table 1: County

- Level Design Value Concentrations for NO 2 1

- Hour NAAQS

State County Site 2011

- 2013 1

- hr Design Value (ppb)

California Alameda 060010011 50

California Butte 060070008 37

California Contra

Costa 060131004 40

California Imperial 060250005 64

California Kern 060296001 46

California Kings 060311004 46

California Los Angeles 060371701 64

California Marin 060410001 45

California Monterey 060531003 3510 Table 1: County

- Level Design Value Concentrations for NO 2 1

- Hour NAAQS

State County Site 2011

- 2013 1

- hr Design Value (ppb)

California Napa 060550003 39

California Placer 060610006 50

California Riverside 060655001 39

California Sacramento 060670002 43

California San

Bernardino 060712002 62

California San Diego 060732007 73

California San

Francisco 060750005 68

California San Joaquin 060771002 53

California San Luis

Obispo 060798001 38

California San Mateo 060811001 45

California Santa

Barbara 060831008 36

California Santa Clara 060850005 51

California Solano 060950004 42

California Sutter 061010003 47

California Tulare 061072002 52

California Ventura 061112002 37

California Yolo 061130004 34 Oregon Multnomah 410510080 34

Nevada Washoe 320310016 5611



### Figure 8 : Trends

- Concentrations for NO 2 

### 1

- Hour NAAQS

- Washington

Figure 9 : Trends

- Concentrations for NO 2 

### 1

- Hour NAAQS

- California12



### Figure 10 : Trends

- Concentrations for NO 2 

### 1

- Hour NAAQS

- Idaho13 

### Figure 11 : Trends

– Concentrations for NO 2 

### 1

- Hour NAAQS

- Nevada

Sulfur Dioxide (SO 2 )

The level of the 1

- hour NAAQS for SO 2 is 75 ppb calculated as the 3

- year average of the 99th percentile of the annual distribution of daily maximum 1

- hour average concentrations. The 2011

- 2013 design

values also calculated as the 3

- year average of the annual distribution of daily maximum 1

- hr average

concentrations for SO 2 are presented in Table 2. Daily maximum 1

- hr SO 2 2000

- 2013 trends at monitoring stations in Oregon, Washington, C alifornia, Idaho, and Nevada are in Figures 12

- 16

.14 Table 2 : County

- Level Design Value Concentration s for S O 2 1

- Hour NAAQS

State County 2011

- 2013 1

- Hour Design Value (ppb)

CA Alameda 15

CA Contra Costa 14

CA Riverside 3

CA Sacramento 2

CA San Bernardino 5

CA San Diego 1

CA San Luis Obispo 21

CA Santa Barbara 36

CA Santa Clara 13

CA Solano 4

ID Caribou 40

NV Clark 8

NV Washoe 6

OR Multnomah 6

WA Clallam 1



### Figure 12 : Trends

– SO 2 

### 1

- hour NAAQS concentrations

– Umatilla County, Oregon15



### Figure 13 : Trends

– SO 2 

### 1

- hour NAAQS concentrations

- Washington

Figure 14 : Trends

– SO 2 

### 1

- hour NAAQS concentrations

- California16



### Figure 15 : Trends

– SO 2 

### 1

- hour NAAQS concentrations

- Idaho

Figure 16 : Trends

– SO 2 

### 1

- hour NAAQS concentrations

- Nevada17

Lead (Pb):

The level of the 2008 NAAQS for lead is 0.15 μg/m3 not to be exceeded in any 3

- month period. The

2011

- 2013 available d esign values for P b are presented in Table 3. Daily maximum 1

- hr Pb 1990

- 2013 trends at monitoring stations in Oregon, California, and Idaho are i n Figures 1 7

- 1 9

.

Table 3. Site

- Level Maximum Design Value Concentrations for 2008 Lead NAAQS, 2011

- 2013

State County AQS Site ID 2011

- 2013 Design

Value (μg/m 3 )

California Imperial 060250005 0.03

California Los Angeles 060371103 0.01

California Los Angeles 060371403 0.11

California Los Angeles 060371405 0.46

California Los Angeles 060371406 0.07

California Los Angeles 060371602 0.01

California Riverside 060651003 0.01

California Riverside 060658001 0.01

California San

Bernardino 060711004 0.01

California San Diego 060731020 0.17

California San Mateo 060812002 0.33
Oregon Yamhill 410711702 0.05

T he d esign values in bold in Table 3 exceed the 2008 Pb NAAQS. The monitoring site in California is

8 00 miles from the Oregon border. Given the great distances involved and the nature of lead transport

, Oregon emissions are not expected to have any effect on lead levels measured in California.

Figure 17 below show s l ocal 2005

- 2013 Pb trends in Oregon . Figures 18

- 20 show Pb trends in Idaho

, California and Washington

. According to EPA requirements, the lead emissions monitoring threshold is 0.50 tons per year (tpy). Air quality monitoring agencies are advis ed to use this threshold to determine if an air quality monitor is required to be placed near a facility emitting lead. There are no Pb trends for Nevada because Nevada did not conduct ambient monitoring for Pb. The figures show Pb trends in Oregon and its neighboring states are going down.18



### Figure 1 7 : Annual Maximum 3

- Month Average Pb

- Oregon

Lead NAAQS is 0.15 mg/m 3 which equals 150 ng/m 3



### Figur e 1 8 : Annual Maximum 3

- Month Average Pb

- Idaho19



### Figure 1 9 : Annual Maximum 3

- Month Average Pb

- California

Figure 20: Quarterly Maximum Concentrations Pb

– Washington20

Fine Particulate Matter ( PM 2.5 ):

The level of the 2012 NAAQS for PM 2.5 is 1 2 ug/m3 calculated as a 3

- year average of the annual

arithmetic mean

. Table 4 presents t he 2011

- 2013 d esign values for PM2.5

. Figures 5

- 10 present a nnual

PM2.5 2000

- 2013 trends at monitoring stations in Oregon, Washington, California, Idaho and Nevada

.

Table 4 PM2.5 Site Listing, 2011

- 2013

State County Site ID 2011

- 2013

Annual Design

Value (μg/m3)

California Alameda 060010007 7.6

California Alameda 060010009 10.0

California Butte 060070008 10.1

California Calaveras 060090001 8.4

California Colusa 060111002 7.1

California Contra

Costa 060130002 7.4

California Fresno 060190011 15.4

California Fresno 060192009 7.8

California Fresno 060195001 16.4

California Fresno 060195025 14.7

California Humboldt 060231002 6.2

California Imperial 60250005 14.3

California Imperial 060250007 7.5

California Imperial 060251003 7.4

California Inyo 060271003 7.5

California Kern 060290014 16.4

California Kern 060290016 17.3

California Kings 060311004 17.0

California Lake 060333001 3.8

California Los 060370002 11.221 Table 4 PM2.5 Site Listing, 2011

- 2013

State County Site ID 2011

- 2013

Annual Design

Value (μg/m3)

Angeles

California Los

Angeles 060371002 12.8

California Los

Angeles 060371103 13.0

California Los

Angeles 060371201 10.2

California Los

Angeles 060371302 12.2

California Los

Angeles 060371602 12.0

California Los

Angeles 060374002 11.1

California Los

Angeles 060374004 11.0

California Madera 060392010 18.1

California Marin 060410001 9.5

California Merced 060470003 13.3

California Merced 060472510 11.1

California Monterey 060531003 6.1

California Nevada 060570005 4.6

California Nevada 060571001 7.0

California Orange 060590007 10.7

California Orange 060592022 8.2

California Placer 060610006 7.5

California Plumas 060631006 10.2

California Plumas 060631009 12.2

California Plumas 060631010 12.8

California Riverside 060650009 7.722 Table 4 PM2.5 Site Listing, 2011

- 2013

State County Site ID 2011

- 2013

Annual Design

Value (μg/m3)

California Riverside 060651003 11.5

California Riverside 060652002 7.7

California Riverside 060655001 6.4

California Riverside 060658001 13.4

California Riverside 060658005 15.1

California Sacramento 060670006 10.4

California Sacramento 060670010 9.5

California Sacramento 060674001 9.3

California San Benito 060690002 5.5

California San

Bernardino 060710025 12.6

California San

Bernardino 060712002 12.6

California San

Bernardino 060718001 8.7

California San

Bernardino 060719004 11.8

California San Diego 060730001 9.9

California San Diego 060730003 10.6

California San Diego 060731002 10.7

California San Diego 060731010 10.8

California San Diego 060731016 8.7

California San

Francisco 060750005 9.2

California San Joaquin 060771002 13.8

California San Joaquin 060772010 10.2

California San Luis

Obispo 060792004 8.723 Table 4 PM2.5 Site Listing, 2011

- 2013

State County Site ID 2011

- 2013

Annual Design

Value (μg/m3)

California San Luis

Obispo 060792006 6.6

California San Luis

Obispo 060792007 11.3

California San Luis

Obispo 060798001 7.0

California San Mateo 060811001 9.3

California Santa

Barbara 060830011 9.5

California Santa

Barbara 060831008 7.6

California Santa Clara 060850002 8.0

California Santa Clara 060850005 10.3

California Santa Cruz 060870007 6.3

California Shasta 060890004 5.7

California Shasta 060893004 6.2

California Siskiyou 060932001 6.3

California Solano 060950004 9.6

California Sonoma 060970003 8.4

California Stanislaus 060990005 13.6

California Stanislaus 060990006 15.7

California Sutter 061010003 7.7

California Tehama 061030006 8.1

California Tulare 061072002 16.6

California Ventura 061110007 9.1

California Ventura 061110009 8.1

California Ventura 061112002 9.1

California Ventura 061113001 9.024 Table 4 PM2.5 Site Listing, 2011

- 2013

State County Site ID 2011

- 2013

Annual Design

Value (μg/m3)

California Yolo 061131003 7.2

Idaho Ada 160010010 9.1

Idaho Bannock 160050020 7.7

Idaho Benewah 160090010 9.9

Idaho Canyon 160270002 10.8

Idaho Franklin 160410001 8.0

Idaho Lemhi 160590004 12.0

Idaho Shoshone 160790017 12.8

Nevada Clark 320030540 8.1

Nevada Clark 320030561 8.8

Nevada Clark 320031019 4.6

Nevada Washoe 320310016 7.6

Oregon Crook 410130100 9.8

Oregon Harney 410250003 9.5

Oregon Jackson 410290133 10.9

Oregon Josephine 410330114 8.8

Oregon Klamath 410350004 11.6

Oregon Lake 410370001 11.1

Oregon Lane 410390060 7.0

Oregon Lane 410391009 5.8

Oregon Lane 410392013 9.1

Oregon Lane 410399004 7.1

Oregon Multnomah 410510080 8.1

Oregon Umatilla 410590121 7.6

Oregon Washington 410670004 8.2

Washington King 530330057 10.125 Table 4 PM2.5 Site Listing, 2011

- 2013

State County Site ID 2011

- 2013

Annual Design

Value (μg/m3)

Washington King 530330080 6.1

Washington King 530332004 7.1

Washington Pierce 530530029 7.8

Washington Snohomish 530610005 5.9

Washington Snohomish 530610020 6.9

Washington Snohomish 530611007 7.7

Washington Spokane 530630021 8.0

Washington Yakima 530770009 9.1

There are design values that exceed the annual PM 2.5 NAAQS in neighboring states at monitoring sites located hundreds of miles away from Oregon. Oregon’s PM 2.5 emissions are unlikely to significantly

contribu t e to those levels

.

Figure 20 shows a nnual PM 2.5 2000

- 2013 NW trend s at monitoring stations in Oregon, Washington,
California, Idaho, and Nevada . The trend shows an 11% regional decrease in PM 2.5 emissions across the NW region.



### Figure 2 1

- A nnual PM 2.5 2000

- 2013 NW Trend

Consultation with Neighboring States : In March 2015, DEQ contacted the air quality agencies in neighboring

states via email

- Adele Malone (Nevada ), Mike Edwards ( Idaho ), Sylvia Vanderspek ( California ), and Paul26 Mairose (Washington)

- regarding the potential transport of air emissions (NO 2 , SO 2 , Pb and PM2.5 ) across state boundaries . T hey informed DEQ that emissions from Oregon do not appear to be impacting their states in a significant way. Specifically, ot her than wildfires, California is not aware of any Oregon air emissions that

affect No rthern California. Washington’s recent interstate transport report indicates Oregon’s emissions are not significantly affecting Washington. Idaho reported that since they do not have a lead, NO 2 or SO 2 non

attainment area, they do not believe Oregon is aff ecting Idaho. Due to the lack of any nonattainment or maintenance areas for the listed pollutants, Nevada concludes that emissions from Oregon are not currently affecting air quality in any significant way.

IV. Nature and Extent of Expected Pollutant T ransport

NO 2 and SO 2 and Pb nor mally do not transport over long distances. As NO 2 and SO 2 can also react in the atmosphere to become nitrate and sulfate particulate , b oth NO 2 and SO 2 will most likely either disperse in the atmosphere or chemically react to form a secondary pollutant within a few miles of the source. Pb would most likely be deposited within a few miles of a source. Based on monitoring data and DEQ’s discussion with oth er state air agencies, DEQ concludes that direct emissions of Pb, NO 2 and SO 2 do not cause or contribute to

exceedance s of the NAAQS. Any impacts from those pollutants as well as PM 2.5 are addressed though DEQ’s

P SD rules and th r ough the Regional Haze program

.

Nitrogen Dioxide : NO 2 is one of a group of highly reactive gasses known as "oxides of nitrogen," or "nitrogen oxides (NOx)." Other nitrogen oxides include nitrous acid and nitric acid. EPA’s N AAQS uses NO 2 as the indicator for the larger group of nitrogen oxides. NO 2 forms quickly from emissions from cars, trucks and buses, power plants and off

- road equipment. In addition to contributing to the formation of ground

- level ozone, and fine particle pollution, NO 2 is linked with a number of adverse effects on the respiratory system.

EPA first set standards for NO 2 in 1971, setting both a primary standard (to protect health) and a secondary standard (to protect the public welfare) at 0.053 parts per billion (ppb) , averaged annually. EPA reviewed the
standards twice since that time, but chose not to revise the annual standards at the conclusion of each review. In January 2010, EPA established an additional primary standard at 100 ppb , averaged over one hour

. C on centrations of N O 2 emitted into the atmosphere will decrease during transport through three mechanisms: deposition, chemical transformation, and dispersion. Interstate transport of NO 2 is not a concern for Oregon due to the distances involved for large stationary sources and large c oncentrations of area source emissions in

western Oregon.

Sulfur Dioxide : S O 2 is one of a group of highly reactive gasses known as “oxides of sulfur.” Generally the largest sources of SO 2 emissions are from fossil fuel combustion at power plants (73%) and other industrial facilities (20%). Smaller sources of SO 2 emissions include industrial processes such as extracting metal from ore, and burning high sulfur containing fuels in locomotives , large ships, and non

- road equipment. SO 2 is linked with a number of adverse effects on the respiratory system. The emission inventory for Oregon demonstrates a

similar source distribution

.

EPA first set standards for SO 2 in 1971. EPA set a 24

- hour prima ry standard at 140 ppb and an annual average standard at 30 ppb (to protect health). EPA also set a 3

- hour average secondary standard at 500 ppb (to protect the public welfare). In 1996, EPA reviewed the SO 2 NAAQS and chose not to revise the standards. In 2010, EPA revised the primary SO 2 NAAQS by establishing a new 1

- hour standard at a level of 75 ppb. EPA revoked the two existing primary standards because they would not provide additional public health protection.27 C oncentrations of SO 2 emitted into the at mosphere decrease s during transport through three mechanisms: deposition, chemical transformation, and dispersion. Interstate transport of SO 2 is not a concern for Oregon due to the distances involved for large stationary sources and large concentrations of area source emissions in western Oregon

.

Lead : As noted in the EPA’s October 14, 2011 Pb infrastructure guidance, the physical properties of Pb prevent emissions from experiencing the same travel or formation phenomena as fine particulate matter or ozone. More specifically, there is a sharp decrease in Pb concentrations, at least in the coarse fraction, as the distance from a Pb source increases. Accordingly, while it may be possible for a source in a state to emit Pb in a location and in quantities that may contribute significantly to nonattainment in, or interfere with maintenance by, any other state, EPA anticipates that this would be a rare situation ( e.g., where large sources are in close proximity to state

boundaries ) . EPA’s experience with ini tial Pb designations suggests that sources that emit less than 0.5 tons per year or that are located more than two miles from a state border generally appear unlikely to contribute significantly to nonattainment in another state. A ll sources of Pb emission s in Oregon are below 0.5 tons per year and are located greater than two miles from the state border . Therefore, it is unlikely that sources in Oregon will significantly contribute to nonattainment or interfere with maintenance of the 2008 Pb NAAQS in

any other state.

Fine Particulate Matter : DEQ’s consultation with air agencies in adjacent states suggests that high PM 2.5 levels in their respective communities are driven largely by local pollution sources during air stagnation events.

Local air stagnation events would generally preclude interstate air pollution transport as a significant contributor to high PM 2.5 levels jeopardizing NAAQS compliance.

V. Sources of P ollutant E missions N ear the State Boundary and E xpected I mpacts in

N eighboring States

.

This section addresses sources and emission s for p ollutant s (s pecifically major point or area source emissions and their proximity to the s tate boundary ) and the l ikel i hood that emissions from these sources would transport

across the s tate boundary to contribute significant ly to nonattainment or interfere with maintenance of any applicable NAAQS in any other state.

There are six Title V Oregon sources (major industrial sources that have a potential to emit a 100 tons per year of any criteria pollutant) in close proximity to the Washington border and one source in close proximity to the

Idaho border.28 Georgia

- Pacific Consumer Products LP, Cascades Tissue Group

- Oregon, Portland General Electric Company
Beaver Plant/Port Westward I Plant, and Portland General Electric Company Coyote Springs Plant all went through PSD analysis, were issued PSD permits and thus demonstrated that their emissions do not cause or contribute to a violation of any applicable NAAQS.

Owens

- Brockway Glass Co ntainers and Evraz were evaluated as part of the competing sources inventory during both Port Westward and Troutdale Energy Center’s PSD analyses and thus demonstrated that their emissions considered in conjunction with the emissions from other sources in the area do not cause or contribute to a violation of any applicable NAAQS.

A PSD permit applicant must conduct an air quality analysis of the ambient impacts associated with the construction and operation of a proposed new source or modification. The pu rpose of the air quality analysis is to demonstrate that new emissions from a proposed major stationary source or major modification, in conjunction with other applicable emissions from existing sources (including secondary emissions), will not

cause or co ntribute to a violation of any applicable NAAQS.

Portland General Electric’s coal

- fired power plant is located in Boardman, Oregon, 14 km south of Washington’s border. It is the only coal fired power plant in Oregon. In December 2010, the Environmental Qu ality Commission approved DEQ's proposed revisions to air pollution control rules for this plant. Based on the adopted rules, Boardman has a federally enforceable shutdown date of December 31, 2020. The rules also require PGE Boardman to use dry sorbent in jection controls to meet federal regulations for sulfur dioxide control and a more stringent sulfur dioxide limit from 2018

- 2020. DEQ concluded that the proposed BART controls, when combined with the permanent closure of plant no later than December 31, 20 20, meet federal requirements and provide a significant environmental and public health benefit.

Based on the analysis discussed above, it is reasonable to conclude that emissions from sources in Oregon do not significantly contribute to PM2.5 and NO 2 con centrations in any other state.

Regional Work with Western Regional Air Partnership (WRAP) : In late 2010, WRAP initiated the West

- wide
Jump

- start Air Quality Modeling Study (WestJumpAQMS) . The goal of the study was to develop the next generation of regional air quality modeling databases for ozone, PM2.5 , visibility and deposition planning in the western U.S and to provide information on the role of interstate and international transport t o ozone and PM2.5 under current and potential future NAAQS. The study looked at PM2.5 annual source apportionment but did not look at the transport of lead, NO 2 or SO 2

. DEQ reviewed Appendix E, State Contributions to Modeled Annual

PM 2.5 Concentrations in 2008 by Monitoring Site

, and the total annual PM2.5 modeled concentrations in all the counties in the state of Washington, California, Idaho, Nevada, and as far away as Wyoming. Clark and Skamania counties in Washington may be impacted by Oregon’s PM2.5 e missions from Georgia Pacific Consumer Products located in Clatskanie. However, Washington does not have an annual PM2.5 nonattainment area and has not had any violations of the PM2.5 NAAQS in the past 3 years. Any potential impact does not result in Orego n’s contribution to nonattainment or violations of annual PM2.5 standard in the state of Washington. The impacts by Oregon to other neighboring states were insignificant.29 VI. Conclusion

In general air pollution from all sources transport across state boundaries. Based on the information described
above ( Oregon ’s emissions inventory, air monitoring dat a and consultation with neighboring state air agencies ),
DEQ finds no evidence to sugges t that Oregon emission of NO 2 , SO 2 , Pb and PM2.5 significantly contribute t o exeedances or violations of NAAQS, or cause adverse effects in the neighboring states. Additionally, Oregon’s PSD program requires NAAQS and visibility analysis for any new or mod ified industrial sources.

In conclusion, Oregon’s SIP complies with CAA S ection 110(a )( 2)(D)(i)(I) . T h e current Oregon SIP contains adequate provisions prohibiting any source or other type of emissions activity within the State from emitting any air pollutant in amounts that will contribute significantly to nonattainment in, or interfere with maintenance by, any other State with respect to any such nation al primary or secondary ambient air quality standard.