JanetNapolitano Governor 1110West Washington Street Phoenix, Arizona 85007 (602) 771-2300

# - www.adeq.state.az.us Stephen A. Owens Director

December 22,2004



### Mr. Wayne Nastri, Regional Administrator 

### U. S. Environmental Protection Agency, Region IX Mail Code: ORA-1 

### 75Hawthorne Street SanFrancisco, CA 

### 94.1 05
Re: Withdrawal ofthe FinalstateIilzplenzentatiorzPlanfor the Douglas PMloNonattainnzeni Area,April 

### 1993
Dear Mr. Nastri:
Thepurpose of this letter is to request that the Final State In7plementation Planfor the Douglas PMloNonattainment Area, April 

### 1993,be withdrawn from coilsideration for any further action by the Enviroiunental Protection Agency (EPA). Based on new analyses and a clean air quality record, the Arizona Department of Enviromnental Quality (ADEQ) is cui-rently worlting to update the Arizona State Imple~nentatioil Plan (SIP) forthe Douglas area.
The consolidated Douglas/Paul Spur area was designated and classified as a inoderate PMlononattainment area by operation of law upon enactment of the 1990 Clean Air Act Amendments. As a result of the nonattai~unent designation, the State was required to submit a SIP for the area to provide for iinplementation and maintenance ofthe PMloair quality standards. During the SIP developinent process, ADEQ determined that the priinary sources of ambient Phllo concentrations contributing to nonattaiiient in the Douglas and Paul Spur areas were unique, and different control strategies were required to address the PMloconcentrations 

### in each area. For example, a lime plant was the primary source category in the Paul Spur area while road dust and pollutant transpol-tacross the United StatesIMexicoborder were the priinary sources of PMlo in the Douglas area. As such, air quality pla~lning for each area was addressed under a separate process. 

### I.p 1993,ADEQ submitted to EPA the PMlo SIP for the Douglas Area which included an assessinent of emissions and ambient impacts as well as implemented control strategies. The SIP for the Douglas area noted that because of inadequate control of einissions in Mexico, violations of the PMloair quality standards were expected to continue. Since that time, however, ambient air quality monitoring data demonstrate that the Douglas area has attained both the a~ulual and 24-hour PMlostandards with no recorded violations since at least 1994. Based on tlis

Northern Regional Office Sout1iel.n Regional Office 1515 East Cedar Avenue * Suite F a Flagstaff, AZ 86004 400 West Congress Street Suite 433 Tucson, AZ 85701 (928)779-0313 (520)623-6733
Printed on recycled papei

### Wayne Nastri December 22,2004 Page 2

information, ADEQ is currently working to develop 

### an updated plan for the Douglas nonattainment area including additional illformationto support separate nonattainment boundaries for the Douglas and Paul Spur areas. As ADEQ moves forward to updatethe SIP,we are committed to ensuring that the air quality progress made through the years will be sustained with appropriate control strategies in place. We welcome and encourage EPA's participatioil as we work to develop a plan that will allowEPA to redesignate the Douglas area to attainment. If you have any questions regarding this request, please coiltactNancy Wrona, Director, Air Quality Division, at (602) 771-2308.

cc: Colleen McKaughan, EPA