# regon
Theodore R. Kulongoski, Governor
December 22, 2010 Dennis McLerran, Regional Administrator U.S. Environmental Protection Agency, Region 10 1200 Sixth Avenue Seattle, WA 98101 

### Department ofEnvironmental Quality Headquarters

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### II I ': FAX (503) 229-6124 

### DEC 

# 2 32010**~'j'** TTY (503) 229-6993 OFFICE OF THE EXECUTIVE

RE: Revision to the Oregon State Implementation Plan: Correction to the Infrastructure Rule Changes Dear Mr. McLerran: The Oregon Department ofEnvironmental Quality inadvertently left outthe report addressing the interstate transport ofozone and fine pa,ticuJate matter when we submitted the request for approval of revisions to the Oregon State Implementation Plan (SIP) fi'om the Office ofAir, Waste, and Toxics, State and Tribal Air Programs Unit ofthe U.S. EPA, Region 10 on June 23,2010. The Environmental Quality Commission adopted the "Oregon SIP Infrastructure for Addressing the Interstate Transport ofOzone and Fine Particulate Matter" as part ofthe revisions to the SIP under OAR 340-200-0040 on April 30, 20IO. DEQ submits this correction to EPA as part ofthe SIP and pursuantto 40 CFR 51.104. I certify thatpublic notices that included the "Oregon SIP Infrastructure for Addressingthe Interstate Transport ofOzone and Fine Particulate Matter" report were published in newspapers ofgeneral circulation onNovember 17,2009, and in the Secretary ofState's Oregon Bulletin on December 1,2009. The notices included a statementthat adoption ofthe rules would revise the SIP. I further celtifythat a public hearing was held on December 18, 2009 in Oregon. Thankyou for your assistance with this correction to Oregon's infrastructure rule changes SIP. We have attached the interstate transport report and the revised SIP submittal documents. The staffcontactfor this correction is Carrie Capp, Air QualityPlanning, at 503-229-5035, and Margaret Oliphant, SIP Coordinator, at (503) 229-5687. 

# ;;12

incere ,

# ··-u~L:. -------. Dick Pedersen, Director

cc w/attachments:
cc w/o attachments: DonnaDeneen, EPA, Region 10 (3 complete sets plus 2 additional copies of revised rules, Attachment 3) Margaret Oliphant, DEQ Air Quality SIP Coordinator Andrew Ginsburg, DEQ Air QualityAdministrator Paul Koprowski, EPA Oregon Operations office

# -Attachments: Attachment 1: Evidence that the state has adopted the revision 1.1 StaffReport, Agenda Item L ofthe April 28-30, 2010 EQC Meeting Also see Certificate and Order for Filing Permanent Administrative Rules in Attachment 4.2 Attachment 2: Evidenced thatthe State has the necessary legal authority 2.1 See Attachment 1.1 "CommissionAuthority" (page 2 ofStaffReport, Agenda Item L, April 28-30, 2010 EQC Meeting) Attachment 3: Provisions Submitted for Approval, Effective May 21, 2010
_____- , 3.1 Redline/Strikeout Version ofadopted,**amend~rro:repealed** SIP rules General Air Pollution proceduresznd Denruons: OAR 340-200-: 0020, 0025, 

## '--;r6 W-t 0040. , , 0""'-" Ambient Air Quality

### Standa~a 

## a PSD Increments: OAR 340-202-: 0060,

### £l..~'l:..t.c,
, 0090,0130. /. l "", Designation ofAir Qy,trflty Areas: OAR 340-204-: 0010,0030.
. ,J1))(**Airpollut~'onEl**ergencies: OAR 340-206-: 0010, 0030.**~e** 'iJ"'" 3.2 Adopted an mended SIP rules submitted to Secretary ofState**~:cj1** 3.3 O.regon?· Infrastructure for Addressing the Interstate TranspOli ofOzone an.5!.-t/a.-;' Fme>li)-articulate Matter v 

### \r-

....IU)

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## ,., Attachment 4: Evidence that the State followed the Administrative Procedures Act**----------------;4-:-1--Public-notice-in-tire-Secretmy-of-State'-s-0regon-Bulletin-Becemher-1-;-200~--------** 4.2 Certificate and Order for Filing PermanentAdministrative Rules, filed and effective May 21, 2010 Attachment 5: Evidence ofadequate public notice 5.1 Affidavit ofPublication: The Oregonian, Notice ofNovember 17,2009 publication Attachment 6: Certification ofpublic hearing 6.1 See paragraph three ofcover letter and Attachment 7.1
Attachment 7: Compilation ofPublic Comments and Department's Response

--------------- 

## - .Tr--preSidingDffTcii'sRep()rtIorRu.lerrlakiilg-Reaiing--()-riDeceinber n,-:W09,-dateo April 29, 2010 7.2 Summary ofPublic Comments and Agency Responses, dated December 31,2009

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### x 1


### x 1.1


### x 2


### x 2.1


### x 3 

### x x 3.1 

### x x

X 3.2
X 3.3
X 4 X 4.1
X 4.2

-------- X 5 X 5.1 X 6 X 6.1 X 7 X 7.1 X 7.2 Evidence the State has Adopted the Revision
Staff Report, Agenda Item Lofthe April 28-30, 2010 EQC Meeting See also Certificate and Order for Filing Permanent Administrative Rules in Attachment 4.2 Evidence that the State has the Necessary legal Authority See Attachment 1.1 "Commission Authority" (page 2 ofStaff Report, Agenda Item L, April 28- 30, 2010 EQC Meeting) Provisions Submitted for Approval, Effective May 21, 2010 Redline/Strikeout Version of adopted, amended and SIP rules General Air Pollution Procedures and no-tin·i(tin Ambient Air Quality Standa**AaOp]~eo** and amended SIP rules submitted to Secretary ofState SIP Infrastructure for Addressing the InterstateTransport ofOzone and Fine

Evidence that the State followed theAdministrative Procedures Act

Public notice in the Secretary ofState's Oregon Bulletin December 1,2009 Certificate and Order for Filing Permanent Administrative Rules, filed and effective May 21, 2010 Evidence ofAdequate Public Notice

Affidavit of Publication: The Oregonian, Notice of November 17,2009 publication Certification of Public Hearing

See paragraph three of cover letter and Attachment 7.1 Compilation of Public Comments and Department's Response

Presiding Officer's Report for Rulemaking Hearing on December 22, 2009, dated April 29, 2010 Summary of Public Comments and Agency Responses, dated December 31,2009

# /

## Attachment 3

/",..

..1,...,..// ..-- 

## Provisions Submitted for Approval, Effective 

## M;,9--y"21, 2010

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3.1 RedJine/strikeoutversion ofadopted,**ame~ed** and repealed SIP rules. General Air Pollution Procedures

## a~15efinitions: OAR 340-200-: 0020,0025, 0040. Ambient Air Quality stani:ardS 

# icI PSD Increments: OAR 340-202-: 0060,0090,0130. Designation ofAir Quality eas: OAR 340-204-: 0010,0030. AirPollution Emergenci :OAR 340-206-: 0010,0030.
.

3.2 Adopted and amfed SIP rules submitted to Secretary ofStare. ' 3.3 Oregon SIP Inffastructurefor Addressing the Interstate Transport ofOzone and Fine ParticulateMatter 

# / ' 

# / ,/Attachment 3.3, page 1 

# Oregon SIP Infrastructure for Addressing the Interstate Transport of Ozone and Fine Particulate Matter
Clean Air Act Section 110(a)(2)(D)
Oregon Department of Environmental Quality

November 5,.2009Attachment 3.3, page 2


# Contents
Addressing Interstate Pollutant Impacts under the Clean Air Act..
.............................................. 3 1. Significant Contribution to NMOS Violations
............................................................................5 2. Interfere with Maintenance Requirements
................................................................................ 13 3. Prevention of Significant Deterioration Requirement
.....................................:........................ 17 4. Protect Visibility Requirement
.................................................................................................... 18



### Contact: Carrie Capp Air Quality Division (503) 229-5035

2Attachment 3.3, page 3 

# Addressing Interstate Pollutant Impacts under the Clean Air Act

Overview Some amount orairpollutiontransport occurs routinely across all state borders and across all regions ofthe country. TIus document discusses Oregon's ability to address interstate air pollutiontransport as it relates to four key aspects ofthe Clean AirAct; compliance wjthfederal air quality health standards for 

### PM2.S and ozone, maintenance with federal air quality health standards for 

### PM2.S and ozone, prevention ofsignificant deterioration, and the protection ofwilderness areas and national parks from air pollution that causes "haze" and can degrade visibility. Based onthe information summarized inthe sections that follow, DEQ concludes that particulate and ozone precursor emissions from Oregon sources do not significantly contribute to violations ofnational ambient air quality standards in other states, or interfere with other states efforts to meet air quality standards, prevent significant air quality degradation, or protectvisibility. In developing this submittal DEQ consulted withEPA staffand air quality agencies in Washington, California, Nevada and Idaho. DEQ's conclusions are based on its understanding ofair pollutionproblems in adjacent states, and the emission sources, meteorology (weatherpatterns), and topographic features (mountainranges, -----ete-;-)-that-influenee-air-E}llality-13f0S1sHls-in-thss@-8t:atss'.--.

---------------------- DEQ will collaborate with Washington, Idaho, Nevada, California and other state air agencies whenever necessary to evaluate case-specific air quality problems thatmay involve regional transpOli ofair pollution. DEQ's Section 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. Two recent examples ofDEQ's ability and willingness to address problems involving interstate transport are the Portland-Vancouver ozone attainment and maintenance plans, and Oregon's regional haze plan. The cities ofPortland, Oregon and Vancouver, Washington share a common air shed. Inthe mid 1990s and again in 2007 DEQ collaborated with the Southwest Clean Air Agency (i.e. the air agency withjurisdiction over Vancouver) to develop bistate ozone attainment and maintenance plans. These plans included emission reduction strategies ----n=-=e--=-eaea to attaIn anamaintain compliancevlTtfh-feaetal ozone**stanclarcls:-IIr2008":~09-DE(tworkeQ-­** with the States ofWashington, Idaho and California, as well as Federal Land Managers in developing Oregon's Regional Haze plan. Under that planDEQ adopted several emission reduction strategies, including emission control requirements for the PGE Boardman coal-fired power plant, to reduce the interstate transport ofhaze forming emissions. The map below (Figure 1) illustrates the significant distances and mountain ranges that in many areas separate Oregon from communities in Washington, California, Idaho, and Nevada, and can help limit the long range transport ofair pollution. DEQ's consultationwith air agencies in adjacent states suggests that high 

### PM2.S levels intheir respective communities are driven largely by local pollution sources during events ofair stagnation. Local air stagnation events would generally preclude interstate air pollution transport as a significant contributorto high 

### PM2.S levelsjeopardizing NAAQS compliance. Conceptually, regional emissions from all Pacific Northwest states could play some small role inregional background ozone levels depending onthe location and circumstances; 3Attachment 3.3, page 4 however, based on the discussion presented in this document DEQ concludes that Oregon does not significantly contribute to ozone problems in other states. Ifany future violations ofozone standards occur, Oregon would work with other air agencies and EPA as necessary to evaluate the role of interstate air pollutiontransport. Regarding regional haze pollution, DEQ will continue to work with other states, federal land managers, and others on interstate transport issues for haze pollution through its on-going state Regional Haze planningprocess. Figure 1: Map ofOregon and major mountain ranges

Section llO(a)(2)(D)(i) ofthe Clean Air Act The state ofOregon developed this SIP revision to meet requirements w1der Section 

### 11O(a)(2)(D)(i) ofthe CleanAir Act. In 2006 and 2007 respectively, EPApromulgated revised primary and secondaryNational Ambient Air Quality Standards (NAAQS) for fine partiCulate (PM2.5) and ground level ozone (03). When EPA adopts a new or revised NAAQS, each state must ensure that its SIP is adequate to implement, maintain, and enforce the NAAQS. Among other things, the SIP must meetthe interstate transport requirements ofSection 

### 110(a)(2)(D)(i) ofthe Act. 

### 4Attachment 3.3, page 5 Section 110(a)(2)(D)(i) requires each state to submit a SIP that ensures a state can and will prohibit any emissions source or other type ofemissions activity withinthe state from emitting air pollutants in amounts that will:
. 

### (1) Contribute significantly to nonattainment or interfere with maintenance ofa primary or secondaryNAAQS in another state, or (II) Interfere with measures in another state's SIP to prevent significant deterioration ofair quality or protect visibility. EPA issued guidance to the states on August 15,2006, and additional guidance on September 25, 2009 regarding Section 11O(a)(2)(D)(i) requirements for the 8-hour 

### 0 3 and PM2.5 NAAQS. The state ofOregon relied on both guidances indeveloping this document. The EPA guidance divides Section 110(a)(2)(D) requirements into the following four categories:
• "Significant Contribution" requirement. • "Interfere with Maintenance"requirement. • "Prevention ofSignificant Deterioration" requirement. • "Protect Visibility" requirement. Each ofthese categories is discussed below. 

# 1. Significant Contribution to NAAQS Violations: Section 110(a)(2)(O){I)

The Oregon State Implementation Plan (40 CFR 52 Subpart MM) provides the mechanism required under the Clean Air Actto prohibit as necessary any emissions source or type ofemissions activity withinthe state from emitting air pollutants in amounts that will contribute significantlyto nonattainment in another**st~te** withrespect to the PM2.5 and 8-hour ozone (03) NAAQS. DEQ can and would take action as necessary to assist states in preventing or correcting any violation offederal

____**airgu'!liJyJl~altl1J3ti:lly:ia~ds._** ... .... ___ _____________ _ Location ofNonattailmlent Areas inNeighboring States and General Topography: For PM2.5, the closest nonattainment areas in neighboring states are the Tacoma area (Pierce County) in Washington; the Chico area (portions ofButte County) in California, and the Cache Valley area in Southeast Idaho (portions ofCache County, Utah and Franklin County, Idaho). For Ozone, cunently all areas in Washington, Idaho and northern California are designated as attainment/unclassifiable by EPA. See Figures 2 and 3 for EPAmaps ofcunently designated ozone and PM2.5 nonattainment areas. The area ofhighest Oregon emission densities (Portland Metro area) is separated from ozone and PM2.5 nonattainment areas in Washington, Idaho and California by significant distances and major mountain ranges up to approximately 7,000 feet (see Fig 1). The one exception is the PortlandVancouver metro area, which shares a common air shed between Oregon and Washington. As 

### 5Attachment 3.3, page 6 discussed below, both Portland and Vancouver are in attainment with both the PM2.5 and 8-hour ozone standards. The Portland-Vancouver air shed is managed for ozone underthe bi-state PortlandVancouver ozone maintenance plan. Distances from the Portland-Vancouver Metro areas to neighboring nonattainment areas are significant: Portland to Tacoma, WA

- approx. 120 miles, Portland to Franklin County, Idaho

- approx. 590 miles, Portlandto Seattle, WA

- approx. 145 miles, Portland to central Californianonattainmentareas (e.g. Sacramento, SanFrancisco BayArea, Los Angeles range from approximately 500 to 800 miles. 

### Fi ure 2: EPA Ma ofdesi nated PM2.5 nonattainment areas Re ions 9 and 10 (2009)

6Attachment 3.3, page 8 

### Figure4: Examplewind rose for winterPM2.5 season.

Winter Win9**~.~s(;}s: p~q~rflber** **~ ~J~!1L!~fY.** 

Inthe PacificNorthwest, exceedances ofthe 8-hr ozone standard occur inthe summer months. In Oregon, prevailing winds are predominantly from the north to northwest and wouldpreclude any significant influence from Oregon on Washington ozone nonattainment areas (see Figure 5). Prevailing summer winds could result in some interstate transport ofozone forming emissions from Oregon to westernIdaho, Nevada and northern California. However as discussed in the sections below, significant distances and topography (such as majormountain ranges that separate Oregon from California, Idaho and Nevada) would likely minimize the significance ofthese impacts on other states. For example, the largest majorurban center in Oregon (the greater Portland area) is approximately 400 to 700 miles away from urban areas in western Idaho, Nevada, and northern California, and is separated by at least one major mountain range (the Cascades). DEQ has consulted with air agencies in each state and concludes that Oregon emissions do notplaya significant role in high ozone levels in others states. Oregon's infrastructure SIP provides DEQ the ability to work with EPA and others states as needed to address regional ozone problems inthe future shouldthey arise.

8Attachment 3.3, page 9 Figure 5: Example wind rose for summer ozone season.
SummerWind Roses: Ju'ly • August

Monitoring: Figures 6 and 7 showthe distribution of2008 federal reference PM2.5 and ozone monitoring in Oregon, Washington, Idaho, Nevada and Califomia. Inthe sections below, DEQ describes ozone and PM2.5 attainment problems areas in these other states, as well as likely contributing sources based on conversations with other state air agencies. Monitoring data in all states is reviewed routinely by air agencies and EPA. High PM2.5 or ozone levels thatthreaten the NAAQS

---- ---- -are investigatedasneede-cfto-IdentTtycontributin-gsources, inchiding-ml,Y potentlalroleofillterstatetransport. The state Section 110 infrastructure SIP elements ensure the capacity for each state to coordinate with each other and with EPA to characterize air quality data, i<;lentifY contributing emission sources (both local and regional) and evaluate other factors that mayjeopardize NAAQS compliance.



### 9

### Attachment 3.3, page 10


# AirData Shaded counties hove monitors

Monitor Location: [J PM2.5 (150) Source: US EPA Office of Air and Radiation, AQS Database Wednesday, Oelober 28, 2009 

# AirData Shaded counties have monitors

Monitor Locotion: V 03 (233) Thursday, October**~**2009 10Attachment 3.3, page 11 Modeling: As part ofEPA's initial development ofthe federal interstate air pollution rule, known as CAIR (Clean Air Interstate Rule) EPA modeled air transport to detennine any significant contributions to nonattainment. EPA concludedthat because ofgeography, meteorology, and topography it was reasonable to exclude the Western

# u.s from the CAIRrule. Based on EPA's conclusions, and the information summarized in this document, DEQ believes that additional modeling ofinterstate PM2.5 or ozone transport is notneeded at this time to support DEQ's conclusions. Summary ofConsultation with Washington, Idaho, Nevada, and California; In preparing this document, DEQ consulted with air agency staffin Washington, Idaho, Nevada and Californiato detennine the ozone and PM2.5 nonattainment status ofcommunities, and get a sense of what the local air agencies believe are the likely causes ofair quality concerns or violations ofPM2.5 and ozone NAAQS. The following sections summarize DEQ's discussion with each state air agency and DEQ'sreview ofEPA teclmical support documentation for recent nonattainment area designations. WASHINGTON Washington PM2.5 Nonattainment In December 2007, the State ofWashington recommended that a pOliion ofPierce County (Tacoma area) be designated nonattainment for the 2006 24-hr PM2.5 standard. EPA has conculTed with the states recommended nonattainment area designation and boundary. Pursuant to section 107(d) ofthe Clean Air Act, EPAmust designate as nonattainment those areas that violate the NAAQS and those nearby areas that contributeto violations. The state ofWashington and EPA evaluated nearby counties in the Seattle, Tacoma and Olympia areas for their contributions to fine particulate levels in the Tacoma area; including an assessment ofpollutant emissions, air quality data, population density and degree ofurbanization, traffic, growth, meteorology (including backtrajectories), and topography. Based on this analysis, EPA has designated the Wapato Hills-Puyallup River Area (a portion ofPierce County) as nonattainment for PM2.5. Significant emission sources in the Wapato Hills-Puyallup River area contributing to wintertime

-- -PM2.5-violationsjnclude-outdooLopelLburning(24%),-mobile-sources-(27-%),-fireplace-and-------- woodstove emissions (39%), and miscellaneous other sources (10%). Air emissions from the state of**Or~gon** were not identified by Washington or EPA as a contributor to violations ofthe PM2.5 standard. Portland-Vancouver Interstate Ozone Area The Portland-Vancouver Interstate Ozone Area comprises Portland, Oregon and Vancouver, Washington. The area was a maintenance area for the I-hour ozone standard, and has been meeting the 8-hour ozone NAAQS since the standard was promulgated in 1997. In 2007, the Oregon Department ofEnvironmental Quality (OR DEQ) and Southwest Clean Air Agency (SWCAA, Vancouver, WA) worked together on a modeling analysis and updated ozone maintenance plan that demonstrates that the Portland-Vancouver area will continue to attain the 

### 03 NAAQS through 2015. This bi-state plan will ensure Oregon and Washington emission sources do not interfere with 11Attachment 3.3, page 12 maintenance ofthe ozone NAAQS. EPA is currently reviewing the Portland-Vancouver ozone maintenance plan. IDAHO Idaho PM2.5 Nonattainment EPA has designated portions ofthe Cache Valley area in Southeast Idaho as nonattainment for PM2.5. The nonattainment area boundary encompasses portions ofCache County, Utah and Franklin County, Idaho. In establishing'the nonattainment boundary the State ofIdaho andEPA evaluated information on significant contributing emissions sources, including factors such as an assessment of pollutant emissions, air quality data, population density and degree ofurbanization, traffic, growth, meteorology and topography. ' Franklin County is essentially topographically separate from the restofthe state as it is surrounded bymountain ranges. EPA concludedthat itis very unlikelythat surrounding counties contribute to violations ofPM2.5 standards. EPA further concludes, along withboththe states ofIdaho and Utah, that exceedance levels ofPM2.5 are producedby air inversions and confined to the lower Valley areas. Thus no areas otherthanthe partial county areas in Cache and Franklin Counties are appropriate for consideration withinthe nonattainment area. EPA's conclusion indicates that air emissions from Oregon do not contribute to PM2.5 nonattainment. Oregon DEQ supports this conclusion. Ozone Nonattainment: As Shown in Figure 3, all counties in Idaho are in compliance with federal ozone standards. CALIFORNIA Northern PM2.5 Nonattainment: The Chico area (lower elevation portions ofButte County) is the most northerly area in California currently designated nonattainment for PM2.5. The state ofCalifornia and EPAconducted an analysis to identify emission sources contributing to violations ofthe PM2.5 NAAQS and to designate an appropriate nonattainment areaboundary. This analysis included an evaluation of emissions data (primary and secondary PM2.5 such as S02,NOx, VOC and NH3), as well as air quality data, population density and degree ofurbanization, traffic, groWth, meteorology and topography. 

### An analysis ofair pollutionrose indicates that elevated levels of24-hr PM2.5 concentrations for the Chico area occurs primarily when the wind is from the 'south, but occasionally whenthe wind is from the north. Thepollutant rose analysis also indicates that elevated 24-hrPM2.5 values occur during the cool season, during periods oflow wind speeds. These meteorological conditions wouldpreclude**sig~ificant** airpollutiontransport from Oregon. EPA concludes that the majority ofcontributing PM2.5 emissions is from local residential wood smoke, with some PM2.5 contribution from surrounding county sources. Air emissions from the state ofOregon were not identified by California or EPA as a contributorto violations ofthe PM2.5 standard.

12Attachment 3.3, page 13 OzoneNonattainment: Mid-state ozone nonattainment areas include metro areas such as Sacramento and the San Francisco Bay Area. Distances from the Portland-Vancouver Metro area to mid-state California are on the order of500 miles. More southerlyportions ofCalifornia such as Los Angeles are designated as nonattainment for ozone as well and are on the order of500- 800 miles from Oregon. Oregon DEQ and California air agency staffdo not believe that Oregon contributes to ozoneNAAQS violations in California giventhe long distances involved, topographic features and weatherpatterns that would limit any significant ozone transport from Oregon. NEVADA 

### PM2.S Nonattainment The entire state ofNevada was classified attainrnentlunclassifiable under the 1997 PM2.5 NAAQS. EPA is in agreement with Nevada's recommendationthat the entire state be designated attainmentlunclassifiable based on the 2006 

### PM2.S NAAQS. Nevada Ozone The Las Vegas area was designated as an ozone nonattainment areabased on the 1997 ozone NAAQS. The rest ofthe state was designated as unclassifiable/attainment. Nevadahas recommended the same designations for the 2008 Ozone NAAQS as for the 1997 standards. The air agency for Clark County (SouthernNevada) has conducted detailed studies, emissions inventories, and modeling work to address ozone issues. Study results indicate that Clark County is often impacted by transpOli ofozone and ozone precursors primarily from Southern and Central Califomia; and under certain scenarios, bytransport from areas outside ofthe southwestemregion (including Southern Califomia and Arizona). Nevadahas no data suggesting impacts on ozone concentrations in SouthemNevada caused bytransport from the state ofOregon. Conclusion: Based on the infonnation described above, DEQ concludes that emissions from airpollution sources in Oregon do not significantly contribute to nonattainment ofthe 8-hourozone or 

### PM2.S NAAQS in

_____ otherillates-'-
___________________________________________ ------- -------------------- 

## 2. Interfere with Maintenance Requirements: Section 110(a)(2)(0)(1) The Oregon State Implementation Plan (40 CFR 52 Subpart MM) provides the mechanism required under the Clean Air Actto prohibit as necessary any emissions source or type ofemissions activity within the state from emitting air pollutants in amounts that will interfere with the maintenance of PM2.5 and 8-hour 

### 03 NAAQS in another state. As described earlier in this document, factors such as major mountainranges, significant transport distances, and the nature ofhigh ozone or PM2.5 events (such as seasonal wind flows and winter air stagnation events) make it unlikely that emissions transpOli from Oregonwould interfere with the 13Attachment 3.3, page 14 maintenance ofozone or PM2.S NAAQS in other states. DEQ's Section 110 infrastructure SIP ensures that Oregon DEQ has the ability to paliicipate as needed in future studies on regional air pollutionissues, or collaborate with other states ifair quality concerns are identifiedthat require a case-specific evaluation ofinterstate transport. Oregon's infrastructure SIP also ensures the legal mechanism for DEQ to take action as needed to reduce emissions to help attain ormaintain compliance with federal NAAQS. Topography/Meteorology/Climatology: The same topography and meteorology described in Section 1above applies when evaluating maintenance ofNAAQS in adjacent states. HighPM2.5 concentrations in adjacent states typically occur under winter conditions when air speeds are low andlor localized air inversions occur. Figure 4 above illustrates typical seasonal windpatterns during the winter whenPM2.5 levels are highest. Wind direction is typically variable with the majority of wind speeds less than 8 miles perhour, and a significantportion oflowwinds less than 5 miles per hour. These lowwind speeds and air stagnation conditions do notlend them to long distance air pollution transport. Occasionalhigh 8-hr ozone levels occur inthe summermonths. Prevailing winds in Oregon are predominantly from the north to northwest and would preclude any significant influence from Oregon on Washington ozone nonattainment areas (see Figure 5). Prevailing summer winds could theoretically result in some interstate transport ofozone forming emissions from Oregon to western Idaho, Nevada and northern California. However as discussed in the sections above, significant distances andtopography (such as major mountainranges that separate Oregon form California, Idaho andNevada) would likelyminimize the significance ofthese impacts on other states. For eXalnple, the largest major urban center in Oregon (the greater Portland area) is approximately 400 to 700 miles away from urban areas in western Idaho, Nevada, and northern California, and is separated by at least one major mountainrange (the Cascades). As shown in Figures 6 and 7 and discussed in the next section, EPA's monitoring data for 2006-2008 shows that both PM2.5 and ozone design values in all counties adjacentto Oregon are belowthe PM2.5 and ozoneNAAQS. Monitoring: EPA monitoring data for 2006-2008 shows that both PM2.5 and ozone design values in all counties immediately adjacent to Oregon are belowthe PM2.5 and ozoneNAAQS. Three northern California Counties (not adjacent to Oregon) have PM2.5 or ozone design values above the NAAQS but have not yet been designated nonattainmentby EPA. Plumas and Shasta counties in northem Californiahave 24-lu' PM2.5 design values above the NAAQS. Tehmna County innorthern California has al1 8-hr ozone design value above the ozone NAAQS. Consultation with air agency staffinthese counties suggests theprimary cause ofPM2.5 exceedances are local wintertime woodstove smoke, summertime road dust andwild fire impacts, and possibly some local industry. InPlumas Co, high ozone values are typically experienced whentransport winds are from the southwest, not from the north. Plumas County is downwind from the Sacramento metro area, and southerly winds are thoughtto produce the highest ozone readings. Similarly, in Tehama Co., measurement ofozone transport suggests the main area ofinfluence to be the greater San Francisco BayArea. Ozone transport monitoring inTehmna Co. is located atthe 2000-foot level, and suggests thatpredominant transport winds move pollutionthrough the San Francisco bay/delta areas; blow along the foothills and up to the monitor. 14Attachment 3.3, page 15 No other attainment counties in Washington, Nevada, Idaho, or northern Californiahave design values violating the PM2.5 or ozone NAAQS. Monitoring data and conversations with state and county air agency staff(summarized here and below) supports DEQ's conclusion that Oregon emission sources are not interfering withNAAQS maintenance in adjacent states. Summary ofConsultation with Washington, Idaho, Nevada, and California. As in Section 1above, DEQ consulted with air agency staffin Washington, Idaho, Nevada and Californiato deternline the ozone and PM2.5 status ofcommunities, and get a sense ofwhatthe local air agencies believe are the likely causes ofair quality concerns for maintaining compliance with PM2.5 and ozone NAAQS. The following sections summarize DEQ's discussion with each state air agency and DEQ'sreview ofEPA monitoring data for Washington, Idaho, Nevada, and California. WASHINGTON PM2.5 Maintenance: As shown in Figure 2, with the exception ofthe Tacoma area all other areas in Washington are designated as Unclassifiable/Attainment at this time.! Ifany WashingtonPM2.5 nonattainment areas are identified in the future ODEQ will work withthe Washington Department of Ecology or Southwest Clean AirAgency as neededto evaluate any contribution from interstate air pollutiontransport. DEQ's infrastructure SIP ensures the ability to collaborate with other air agencies on transport analysis when and ifneeded. Ozone Maintenance: As shown inFigure 3, all counties in Washington are currently in attainment willi ozone stanCiarCis. Tlie city or-Seattle currently meets the federal ozone 

### NAAQS. Each summer, Seattle experiences elevated ozone levels thattypically occur under northerly winds (i.e. winds blowing from north to south). This strongly suggests that Oregon emissions sources (approximately 175 miles to the south ofSeattle) have no significant affect on Seattle's summer peak ozone events. If future violations ofozone standards occur in Seattle, or other areas ofWashington, DEQ will collaborate with Washington air agencies as needed to evaluate any contribution from regional interstate air pollution transport. IDAHO PM2.5 Maintenance: In the Northern part ofthe state the community ofPinehurst experiences high

... __**lev~IQ._QfJ)M2~)_and JI~** **~t:lteis**-'Y'QIkingJ¥iili EPA**Q_nstmh;giesJQpr~yenttheare-,iJrom_reaching** __ nonattainment status. The area also has PMI0 issues withthe biggest contributing source being wood stoves. The elevated levels occur during periods ofair stagnation so it is very unlikely other areas in Idaho or interstate transport are contributing to the increased levels ofparticulate. Ozone Maintenance: While cUlTently in attainment status, Boise is seeing monitored concentrations ofozone at levels that are occasionally close to the NAAQS. Idaho DEQ will be closely monitoring these levels and will likely investigate contributing sources. There is no information at this time to suggest any significant contribution from Oregon emission sources. DEQ will collaborate with Idaho DEQ as needed to evaluate any role ofintrastate transport.

140 CFR Ch. 1Part 81 Subpart C Section 107, Attainment Status Designations, 7-1-08 Edition 15Attachment 3.3, page 16 CALIFORNIA PM2.S Maintenance: Modoc, Siskiyou, Plumas, and Shasta counties in northern California experience evaluated PM2.S levels, primarily in the winter due to air stagnations and local sources such as woodstoves, but occasionally in the summer due to wildfire smoke. Occasional exceedances ofthe PM2.5 NAAQS are measured, butno areas have been designated as nonattainment for PM2.S. Wood burning devices are a commonresidential heat source inthese areas, andNAAQS exceedances are thought to be a result ofboth woodstove smoke and coinciding inversions. The Siskiyou mountainrange (approx 6,000 to 7,000 feet) separates western Oregon from Californiaand would help limitthe transport ofair pollution into California. Itis unlikely that Oregon air pollution sources would significantly contribute to NAAQS exceedances in northern California given the local topography, significant distances involved (on the order ofSO to 1OO'miles or more), and the air stagnationmeteorologythat helps produce highwintertime 

### PM2.S levels. Ozone Maintenance: As shown inFigure 3, boththe North CoastAir Basin (Del Norte, Humboldt. Mendicino, Sonoma (part) and Trinity Counties) and theNortheast Plateau Air Basin (Lassen, Modoc, and Siskiyou Counties) are designated as Unclassifiable/Attainmentfor the 2006 Ozone NAAQS. Collectively, these two basins constitute the northernportion ofCaliforniawhere the interstate transport ofOregon ozone forming emissions could potentially occur based on seasonal wind patterns. While northern Californiahas notexperienced any ozone violations, there have been a few days ofelevated levels (summertime events). Califoiniaair agencies may further investigate ozone levels and transport in these areas, and Oregon DEQ can collaborate as needed in such studies; however, DEQ's consultation with air agency staffin these counties suggest thathigh ozone values in these areas are influenced primarily bythe Sacramento or San Francisco areas under northerly winds. There is no evidence to suggest any significant contribution from Oregon. NEVADA 

### PM2.S Maintenance: As shown in Figure 2, the entire state ofNevadahas been classified attainment/unclassifiable under PM2.S NAAQS. Ozone Maintenance: As shown in Figure 3, withthe exception ofthe Las Vegas area in southernNevada, the entire state has been designated by EPA as attainmentlunclassifiable with the ozoneNAAQS. Clean Air Interstate Rule (CAIR) As described in the overview, based on available information Oregon DEQ concludes thatparticulate and ozone precursor emissions from Oregon sources do not significantly contribute to violations of national ambient air quality standards in other states, orinterfere with other states efforts to meet air quality standards. In 2004, EPA reachedthis same conclusion aspart oftheir initial development of the federal interstate air pollutionrule, known as CAIR. CleanAir Interstate Rule (CAIR)

16Attachment 3.3, page 17 Atthe time the CAIRrule (then titled "Ruleto Reduce Interstate Transport ofFine Particulate Matter and Ozone (Interstate Air Quality Rule).,,2 was initially proposed, EPA conducted an analysis to identify states thatwere contributing significantly to nonattainment ofPM2.5 and 0 3 in adjacent states. The Preamble to the proposed federal Interstate Air Quality Rule statedthe following with regard to Oregon: In analyzingsignificant contributions to nonattainment; we determined it was reasonable to exclude the Western US, including the States ofWashington, Idaho, Oregon, California, Nevada, Utah and Arizona fromfurther analysis due to geography, meteorology, andtopography. Basedon these factors, we concludedthat the PM 2.5 and8-hour ozone nonattainmentproblems are notlikely to be affectedsignificantly bypollutiontransportedacross these States' boundaries. Therefore,for the purpose of assessingState's contributions to nonattainment in other States, we have onlyanalyzedthe nonattainment counties located in the rest of the US3 Conclusion: Based onthe information described above, DEQ concludes that emissions from air pollution sources in Oregon do not interfere with the maintenance ofthe 8-hour ozone or PM2.5 NAAQS in other states. 

# 3. Prevention of Significant Deterioration Requirement:**Section-11~Ota~)(z-)·tBl(+)'--------** The state ofOregon concludes thatthe Oregon State Implementation Plan (40 CFR 52 SUbpart MM) provides the mechanism required under the·Clean Air Act to prohibit as necessary any emissions source or type ofemissions activity within the state from emitting air pollutants in amounts thatwill interfere with another state's SIP measures for preventing significant deterioration ofair quality or protecting visibility. Oregon has no EPA designated 8-hour 

### 03 nonattainment areas, and has two designated PM2.5 nonattainment areas. For most ofthe state, Oregon will permit newmajor industrial sources through

___**~** JheJ>reyentiou ofSignificant**Deterioratio!1~{£.SJ2tpJ12gram** fOL1hes.e p<21lulal11s. DEQ's**N.ew$our~e~~~~** Review (NSR) rules ensure that the maintenance ofNAAQS in neighboring states is notjeopardized by new or expanding industrial sources. Specifically, all new industrial sources and major modifications to existing industrial sources in attainment areas are subjectto DEQ PSD rules requiring pre-construction review, air quality analysis, the application ofany required emission control technology, and airpennitting. All new sources and major modifications in nonattainment areas are subject to the nonattainmentNew Source Reviewprovisions ofthese rules, including LAER, offsets, and netting air qualitybenefit. DEQ is on schedule to update the rules to address PM2.5. Oregon's PSD program also includes procedures to address Phase-II requirements ofthe Final Rule to implement the 8-Hour Ozone National Ambient Air Quality Standard.4

2Proposed rule at 69 FR 4566, January 30, 2004. 369 FR at 4581, January 30, 2004. 470 FR 71612, November 29,2005. 17Attachment 3.3, page 18 Non-interference and visibility measures and protection ofClass-I area visibility in neighboring states is achieved through the visibility and Air Quality Related Value requirements ofthe PSD rules. Adjacent states and Federal Land Managers are notified ofany proposed new or expanding major industrial source that may have the potential for significant impacts intheir states orregions and provided the opportunity to review and comment on,air quality analyses. In addition to reviewing any DEQ analysis, Federal Land Managers may also submitvisibility impact analysis to DEQ for consideration during the industrial source permitting process. NewNonattainment Areas for PM2,5 The communities ofKlamath Falls and Oakridge, Oregonhave recently been designated nonattainment for PM2.5 by EPA. Oregon DEQ and the Lane Regional Air Pollution Agency (LRAPA) will develop PM2.5 New Source Review (NSR) procedures as part ofeach community's PM2.5 attainmentplan. These plans, together with supporting rules, will be adopted as an amendment to the state ofOregon SIP. 

# 4. Protect Visibility Requirement: Section 

# 11O(a){2)(D){i){lI) , EPA's Regional Haze regulations required that states submit Regional Haze plans to EPA by December 17, 2007. 5 Most states have been delayed in SUbmitting their regional haze plans (SIP revisions), primarily due to the complexity ofconducting Best Available Retrofit Technology (BART) analysis for selected older industrial sources. Oregon submitted its regional haze planto EPA for review and approval July 14, 2009. Oregon DEQ will continue to collaborate withthe states ofCalifornia, Washington and Idaho, EPA, 'Federal Land'Managers, and Inany others to develop regional strategies for reducing haze across the PacificNorthwest. Oregon's Regional Haze Plan was deemed complete byEPA in September 2009, and is nowbeing reviewed for approval. The plan includes emissionreduction requirements for several older major industrial facilities, including stringentpollution control requirements for Portland General Electric's coal-firedpowerplant near Boardman. The newrequirements will result in significant visibility improvements and reduced pollution for the region's Class I wilderness areas and nationalparks as well as the Columbia River Gorge National Scenic Area.

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. 564

### FR 3517, July 1,1999. 18