UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 10 1200 Sixth Avenue, Suite 900 Seattle , WA 98101-3140



### Stu Clark, Air Quality Program Manager Washington State Department ofEcology PO Box 47600 Olympia, WA 98504-7600 Craig Kenworthy, Executive Director Puget Sound Clean Air Agency 1904 Third Avenue - Suite 105 Seattle, WA 98101 

## NOV

# 202013 OFFICE OF AIR, WASTE AND TOXICS



### Re: Review ofDraft Kent, Seattle, and Tacoma, W A, Second 10-Year Limited Maintenance Plan for Coarse Particulate Matter (PM 10) 

### Dear Mr. Clark and Mr. Kenworthy: We have reviewed the draft version ofthe Kent , Seattle, and Tacoma, WA, Second 10-Y ear Limited Maintenance Planfor PM1 oto identify potential deficiencies prior to final submission for approval by the U.S. Environmental Protection Agency (EPA). We have concluded that the draft version sent to the EPA on September 27, 2013 , would likely be approvable into the Washington State Implementation Plan. However, the EPA will make a final decision based on our review ofthe complete State Implementation Plan that is submitted following your public process and after consideration ofany comments we receive as part ofthe Environmental Protection Agency public process. Ifyou have any questions please feel free to contact me at 206-553-1271 or have your staffcontact Debra Suzuki, Air Platming Unit Manager, at 206-553- 0985 or JeffHunt, stafflead, at 206-553 -0256.



# 0 P ri

nted on Recy cled P aperUNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 1 0 1200 Sixth Avenue, Suite 900 Seattle , WA 98101-3140 O FFIC E OF AIR. WASTE AND TOXICS 

### 10/25113 MEMORANDUM SUBJECT : 

### Review ofDraft Kent, Seattle, and Tacoma Second 10-Year Limited Maintenance Plan for Coarse Particulate Matter (PM 10) 

### FROM: 

### JeffHunt, Air Quality

# Planne**d~** TO: 

### Debra Suzuki, Air Programs Unit Manager The Washington Department ofEcology (Ecology) and Puget Sound Clean Air Agency (PSCAA) asked the Environmental Protection Agency (EPA) Region 10 to review the draft Kent, Seattle, and Tacoma, W A, Second 10-Y ear Limited Maintenance Planfor PM1

## oso that any errors or EPA concerns can be addressed prior to submission ofthe final package to the EPA. Barring significant changes as a result ofpublic comment, Ecology intends to submit a finalized version ofthis draft for the EPA' s approval into the Washington State Implementation Plan (SIP) . Robert Kotchenruther and I coordinated closely with PSCAA and Ecology in reviewing the methodology, inventories, and technical analysis in this draft plan. Generally speaking, it follows the same format and methodology used in the Thurston County Second 10-Y earLimited Maintenance Planfor PM10, 

### which received no public comments and was finalized by the EPA on October 3, 2013 (78 FR 61188) . Similar to the Thurston County maintenance area, all three maintenance areas in PSCAA'sjurisdiction have been attaining the PM 10 

### standard since 1990. PM 10 

### levels have steadily declined well below the limited maintenance plan threshold of98 j.!g/m3 

### (Kent= 46±3 jlg/m3 , 

### Seattle= 50±5 jlg/m3, 

### and Tacoma= 58±8**~tg ,**  

### using a correlated estimation model similar to the Thurston County plan) . Overall, this should be a noncontroversial action. Because the EPA previously received a comment on the fine particulate matter (PM2.5) 

### inventories for Tacoma related to the locomotive transport ofcoal, it is possible we may receive a similar comment in this action. PSCAA and Ecology worked closely with Robert Kotchenruther to develop an estimation oflocomotive inventories, including possible fugitive dust emissions. Total locomotive estimated emissions during the critical winter day period, including locomotive-related fugitive dust, are small relative to other source categories (Kent = 6%, Seattle = 5%, and Tacoma = 2%). Because total locomotive emissions are such a small proportion ofthe inventory and PM 10 

### levels are already quite low and steadily declining, it is my determination that locomotive transport ofcoal will have little to no impact on overall attainment ofthe PM 10 

### standard in these maintenance areas .

### Based on my evaluation ofthe limited maintenance plan criteria, I believe this draft plan meets the Clean Air Act requirements for incorporation into the SIP barring any significant public comments or changes in EPA policy. I included a copy ofmy analysis as Attachment A. Attachment B is a sample Federal Register notice based on the proposed rulemaking 

### Thurston County Second 10-Year PMJO LimitedMaintenance Plan signed by Dennis McLerran on July 22, 2013. Upon final submission, I will review any changes to Ecology's SIP revision along with any comments received during the state or local public comment periods in making my final determination.

2

# Attachment A- EPA Review of PSCAA / Ecology draft: "Kent, Seattle, and Tacoma, WA Second 10-year Limited Maintenance Plan for PM1o" As submitted on: September 27, 2013

The EPA analysis is contained in text 

### boxes, such as this 

### one, throughout the document.

## Table of Contents Executive Summary ... . .. ...... .. .. . ... ... .... . . .. ... .. .. ...... .. ...... ... .. ...... . .... .... ....... .... . ... .. ..... ....... .. .. ... ..... .... .. ... .. ....... .. ..9 1. Introduction .... .................... .. ........ ....... ... ... ....... .. ........ . ... .. .. .... ........... ... .. ... .... .. ................... ........ ... . . ... .10 Particulate Matter Standards .. . ... . ........ ..... ..... ... . ........ .. ... .. . .............. .. ......... .... ....... . ..... .... ......... . ... ... ... 10 Ma intena nee Area Com pi iance History .... .......... .. .............................. .. ........ .. .. .. .. .............. .. .. ........ .... 10 Plan Structure .... ... .... ...... . ........... .. .. ................... ... . .. .. ...... .............. .. ................... ... .. ..... .... .... ......... .. . . .. 11 2. Background .. .. ... ... .... ... ... . .. . .. ... ..... .. ... .. ... ... .. ........................... .. ....... .. ... ............... .. .. .. ... .. .. ..... .. ... ..... . . ... 12 Geographic Area .... ... .... .. . ... .. ..... .. .... . ... .......... .. ... .. ..... ...... ... .. .. .. ........... .. .. ...... . .. .. ... .... .. ... ... ...... .. ..... .. . .. 12 Compliance History ... .. .. ......... .. ................. .... .. .. .. .. ... ... .... ........... .. .... ... ..... ...... ........................ ........ .... . 17 3. Limited Maintenance Plan Option ........ ......... ... .. .. ... .. .. .... .. ... . ... ... .. ..... ... ........... ... . .. .............. .......... . .... 17 NAAQS Qualification Criterion ... .. . ....... ... .............. .................. .. .............. .. ..... .... ... ... .. .. .. ................... .. 18 Design Value Criterion ... ................ ......... .................................................... . ......... .. .. ............. ......... ..... 19 Motor Vehicle Regional Analysis Criterion .... .. .................... .. .... .. .. . .................. ....... .. ....................... .. . 21 LM PQualification .. .. .......... . ................ .. ..... ... .... ... . . .... ... .... . . .. .... .. ......... . .. .. ... .. .... ...... .. . ... ... .. ............. . .. . 22 4 . Particulate Matter Manitoring ....... . .. ... .... . ... .... .. .. . .... ... . ..... .. ...... .... ... ... .... .. . .. ...... .... . . ... . ........ .... .. .........23 4. 1. PM 10 Concentrations ......... . .... . .. ..... .... .. .. ..... .. ..... ...... ... .. .. .. .. .. ..... ... . ..... ......... ...... .. . .. .. .. ........ . ... .............23 Kent Maintenance Area .... ...... .... ... ........ .. ... .... ... .. ........... .. ....... .. ....... .. ... .... .. .. .. ......... ....... ..... .. .... ... .. ... 23 Kent Monitoring .... .. ..... ...... ..... .... . .. ..... .. ... ..... .. .......... . ....... ....... .... ..... .. .. .. .. . .. .. . ....... . .... ... ... ............. ... .. 24 Seattle Maintenance Area .... .. ..... . .. .. ... .. ... .. ..... .. ............ ..... ............ .. ..... .. ...... .. ..... ....... .. .. .. .. . ........ .. .. .. . 26 Seattle Monitoring . . .... ... . .. ........ .. ...... .... ..... ...... . .......... .. .... .. .. .. .. ........ .. .. .. ....... ......... . .. ....... ..... ......... . .. . 26 Tacoma Maintenance Area . ............. ...... ...... ... ...................... .. ................. .... .. ...... . ...... .. .... ........ .. ....... . 28 4.2. Model Development .. .......... .. .. .... .. .. ..... ..... .. ......... ....... .... . . ... ...... ... .. .. ..... ......... ..... .... .. ........... ... ... .. .. .. ..30 Kent ..... ....... . ....... . ...... . ... ...... .. .. . .. .... .. ....... . .. ... . ....... ... .. .. .... . ........ ...... ...... .. ... .. .. .. ......... .. ... ... .. .... ........... . 30 Seattle ..... ... .. ... .. ... ........... .. ......... .... ...... .. . . .. .............. .. .... .. . . ........ .. ... . ........ .... .. .. .. ... .. .. .. ...... .. ........ .. ...... 32 Tacoma ..... .... .. ... ..... .... .... . .. ... ... ..... .... .. ...... . ... ..... .. .. .. .......... . ..... .. ... .. ... .. .. ... .. ...... ... ....... .. ...... .... ... . .... .. .. . 34 PM 10 Violation Unlikely... . ... ... ..... .... .. .. ...... .. ..... .. ............. .. .............. .. .......... .. ..... .. ... ...... . .. .. .. ... .. ...... .. .. . 36 4.3. Current PM 10 and PM 2.5 Data Availability.... .... .. .. .. ................ .... .... . .. ..... .. .. .... .... ...... .. .... .. .. . .... ...... .... .. .. 37 5. Emission Inventory ...... .. ... .. ... ...... ........... . .. . ..... .. ..... .... ..... . . .. ..... .. ... . ... .. .. ... .. .......... .. .... ... .. ... ........... .. .....38 Emission years and categories ............ .. ..... ... . ... .. .. ..... .. ..... ....... .. ... ....... .. .......... .... ... .... ... .. ....... . ... .. .. .. .. 38 iiEmission inventory geography ............................ ........ ....... ....... . .. .. ................ .. ......................... ... . ...... 39 Significant source categories....... ... .... ... ..... ................................... ....... ... .. ..... .... . ... ....... . .............. ....... 39 Maintenance Plan Inventory .... ...... .. . ... .. .... .... . ............. ..... .. ........ . ..... .... ..... ........................ ................. 40 6. Control Measures ................................................................................................................................. 41 Emission Reduction Programs ..... ..... ...... .. .. .. .... ................ ............ .... ... . .. ... ...... .. .......... ... ..... . ... ...... ...... 42 Wood Smoke Curtailment.................... .. ..... .... ................................ . ..................... .... .... .... . ... ..... .......... 42 Fugitive Dust........................................ ................. .... ................................................ ... .... .. .... .............. 43 Industrial Sources ................................................................................................................................ 43 Diesel Emissions .................................. ....... . .. .... ...... .. ............ .. ...... ... . .... ... ..... ...... . .. ... .. . .. ....... . ............. 43 Voluntary diesel emissions reductions: .. ... ... .. ... .... .. ... .. .. ... .. . ... ................................... ...... ... ... . ...... ..... 44 Outdoor burning ... ..... ... . . ... . ... ..... ... . ... .. . ... .... .. ....................... .. ..... ...... . ... . ... ........................................ . 45 Control Measures in PSCAA Rules .. . .... .. ................................................. .. ........ ....... .. .... .. . ... .. ....... ... .... 45 7. Contingency Measures ......................................................................................................................... 47 Contingency Measure Trigger .......... ..... .. ... .......... ..... .. ............................................. ....... ....... .. ........... 47 8. Commitment to Continued Monitoring and Verification of Continued Attainment . ...... .......... ..........48 9. Summary of Maintenance Plan Commitments ....................................................................................49 Appendix A .........................................................................................................................................A-1 Appendix B ... ..... .... . ... . ....... . ............ ..... .............. .. ....................................................... .... ... . ................ B - 1 Appendix C .......................... . .... ..... ........................... . .... .. ...... .... . ... ..... ... ........ .. ............................ . .. .... C-1 Appendix D ....................................................................................... ....... .................................... ..... .. D-1

iii

## Table ofFigures Figure 2.1: The Kent, WA PM 10 Maintenance Area ....................... .. ................ ................. ..................... ..... 14 Figure 2.2 : The Seattle, WA PM 10 Maintenance area ................................................................................ . 15 Figure 2.3: The Tacoma, WA PM 10 maintenance area .................................. .................. ........................... . 16 Table 3.1: Three-year design values calculated using the most recent three years of estimated PM 10 concentrations.................. .... .....................**~** ..................... ....... .. ...... ... ............................ ... .... ............... ....... 18 Table 3.2 : Tabular Estimation of PM10 Design Values3

.................................... ..................... .................... 20 Table 3.3 : Five-Year Design Values for Kent, Seattle, and Tacoma .... .................................. ........ .............. 20 Table 3.4: Margin of Safety Comparison .......................... ....................... .. .... ...... ....................................... 22 Figure 4.1.1: Kent Historical PM 10 Concentrations ............ ............ ............................................................ 23 Figure 4.1.2 : PM10 and PM 2.5 data used to develop the PM 10 to PM 2.5 relationship ................................ 24 Figure 4.1.3 : PM 2.5 monitoring data used to estimate PM 10 concentrations from 2008-present.. ............ 25 Figure 4.1.4: Seattle Historical PM 10 Concentrations .. .... .... .............. .. .... ............................ ...................... . 26 Figure 4. 1.5: PM 10 and PM 2.5 data used to develop the PM 10 to PM 2.5 relationship ...... .. .... .......... .. .......... 27 Figure 4.1.6: PM 2.5 monitoring data used to estimate PM 10 concentrations from 2008-present.. .. .... ..... . 27 Figure 4.1.7: Tacoma Historical PM 10 Concentrations............................................................................ .... 28 Figure 4.1.8: Tacoma monitoring data used to calculate the PM 10 PM 2.5 relationship .......................... . .. . 29 Figure 4.2.1 : Summer and Winter PM 10 to PM 2.5 from 1999-2007 at the Kent Monitoring Site .. .... ......... 31 Figure 4.2.2: Estimated PM 10 to Measured PM 10 for the years 1999-2007 ................ ... ............................ 32 Figure 4.2.3: Summer and Winter PM 10 to PM 2.5 from 1999-2007 at the Seattle Monitoring Site .......... . 33 Figure 4.2.4: Estimated PM 10 to Measured PM 10 for the years 1999-2007 ............................................... 34 Figure 4.2.5: Summer and Winter PM 10 to PM 2.5 from 1999-2007 at the Tacoma Monitoring Site .. ........ 35 Figure 4.2.6: Estimated PM 10 to Measured PM 10 for the years 1999-2007 ................ ............ ................... 35 Table 4 .2.7 PM 2.5 concentrations corresponding to a PM 10 concentration of 150 11g/m 3

......................... 36 Table 5.1: Emission Categories used in this LMP ...................................................................... .. .............. . 39 Table 5.2: Seattle, Tacoma, and Kent Maintenance Area Annual and Winter Day PM 10 Emissions ...... .. .. 40 Table 6. 1 : PSCAA Regulation I- Article 8 : Outdoor Burning .. ........ .. .. ................... .. ........ .... ....................... 45 Table 6.2: PSCAA Regulation I- Article 9: Emission Standards .................... ....... .... .. .......... ....... ................ 45 Table 6.3: PSCAA Regulation I- Article 13 : Solid Fuel Burning Device Standards .................................... . 46 Table 9.1: Second 10-Year LMP Commitments ........................................ ................................. ........... ...... 49 Table A.1: Kent PM10 Maximums and 5-Year Design Values, 1999-2007 ...... ..... ............ .. .... ....... ........... A-3 Table A.2 : Kent, Washington Modeled PM10 5-Year Design Values, 2008-2012 ................................... A-4 Table A.3 : Seattle, Washington PM10 Maximums and 5-Year Design Values, 1999-2007 .................... .. A-5 Table A.4: Seattle, Washington Modeled PM10 5-Year Design Values, 2008 - 2012 .............. .. ............... A-6 Table A.5: Tacoma, Washington PM10 and 5-Year Design Values, 1999-2007 ............ .. ...... ........ .. ......... A-7 ivTable A.6: Tacoma, Washington Modeled PM10 5-Year Design Values, 2008- 2012 ........... ........ . ... . .. ... A-8 Table A.7: Design Values used for Motor Regional Analysis .. ............. ... ......... .... .. ................ .... .... ...... . .. A-10 Table A.8: Projected 10-year Increase in VMT . .. .......... ................... . .. ...... . ........................... .................. A-10 Table A.9: Calculation of Motor Vehicle Design Value ...........................................................................A-11 Table A.10: Margin of Safety Comparison ............ . ............................................ . ................. ... . ........ ....... A-12 Table C.1: List of 2011 Emission Categories .... . ...... .. ...... ......... .. .. ... . ... . .. ....... ......... . ................. .................. C-1 Table C.2: 1994 emission categories with their respective 2011 representative emission category ....... C-1 Table C.3: Spatial surrogate and sources of data for sub-county region (maintenance area) estimates. C-3 Table C.4: Tons of PM10 by wood burning device, King and Pierce County ....... . ... ............. ...... . .... .......... C-5 Table C.5: PM10 Maintenance Area Population Data .. ... .. ................... .... . ........... ................. .................... C-5 Table C.6: Tons of PM10 by wood burning device in each maintenance area: .... ...... .... ............ .. ...... ...... C-6 Table C.7: Paved road dust PM10 emissions with the fraction of the maintenance areas vehicle miles traveled . .. ... .. ........ . ... ........... ........... . ... ...... .. ............................................................ .. .............. .. ...... ....... .. . .. C-7 Table C.8: MOVES Model Parameters and Data Sources ................. ........... . ....... ... ...... .... ....... . ....... ... . ... ... C-9 Table C.9: Onroad mobile PM10 emissions with the fraction ofthe maintenance areas vehicle miles traveled .............. ... ... ......... . .... ............. ......................................... ............................ ... . .. ......... ... ..... ......... C-10 Table C.10: Unpaved road dust PM10 emissions with the fraction of the maintenance areas vehicle miles traveled ........ ... ................... .... ..... . .... .......... ......... .... ..... . ............. . .............. .. ... .. ............. . ......... . ... ... .......... C-11 Table C.11: Fraction of Port Areas in Maintenance Areas .. ... ... .. ......... ... ... ............ ... ...... ... ................. .... C-12 Table C.12: PM10 emissions breakdown in tons of port and marine emissions within each maintenance area by subcategory . .. ... ........ ....................... ............ .............. ..... .. ..... ...................................... .. ........ .. ... C-13 Table C.13: List of emission sources and methods used to estimate locomotive emissions .................. C-14 Table C.14: Values used in the rail coal dust emission factor equation ........................... .. ..................... C-16 Table C.15: Estimated annual locomotive PM10 emissions by category .. ..... ......... ......... ... ... . ........ .. .... . . C-17 Table C.16: Maintenance area fraction of the rail line of the total county rail for estimating passenger and coal dust emissions ... ............. ............ ... ..... ... ..... ........... . ........... . .............. . .. ... .... ... .. .... . .. ....... .... ........ C-18 Table C.17: Fraction of county rail activity in the maintenance area for line haul estimates............ ... .. C-18 Table C.18: The number of industrial sources (active or inactive) reporting PM10 emissions between 1994 and 2011. ...... . ... . ...... . .................................................. . ................................................................... C-19 Table C.19 : PM10 Emissions from all industrial sources from 1994 to 2011: .. ...... ....... ............... .. ...... ... C-20 Table C.20: Estimated annual emissions by reporting industrial source ................................................ C-20 Figure D. 1: The Kent, WA PM10 Maintenance area .......... .... .... .. ..... . ............. ..... ..... ............... ......... ... .. .... D-4 Figure D.2: The Seattle, WA PM10 Maintenance area ...... ... .... .. .......................... ..... .... .... .. . ......... .. .... .... .. D-5 Figure D.3: The Tacoma , WA PM10 maintenance area ... ..... ........ . ............... .. ......... .. ........... .. ... . . ..... ......... D-6 Table D.4: 1994 PM10 Average Daily Emissions from the 1997 maintenance plan ...... ........... ............. ... D-7 Table D.S: Emission Categories to be used in this LMP ........................ .. .... . ..... ......................................... D-8 Table D.6: MOVES Model Parameters and Data Sources ............... ..... ....... ..... ..... . ......... . ....... . .. .. ... . .. ... ... D-10 vTable 0.7: The number of industrial sources (active or inactive) reporting PM10 emissions between 1994 and 2011. .................................................................................................................................................0-12 Table 0.8: PM10 Emissions from all industrial sources from 1994 to 2011: ... .. .. .................................... 0-13 Table 0.9: Spatial Surrogates................................................................................................................... 0-15

vi

## Acronyms and Abbreviations ADVMT....................................... Average Daily Vehicle Miles Traveled AERR ....................................... . .. Air Emissions Reporting Rule AP42 ..... ...................................... EPA's Compilation of Air Pollutant Emission Factors AQI ....................... . ......... . ... .... .... Air Quality Index AQS ........................................... Air Quality System BNSF .... ............ .... ... . ..... .............. Burlington Northern Santa Fe Railway bscat .. ···· ·· ················· ···················· A measure of light scatter, scattering coefficient CAA ... ............ ........... . ................. Clean Air Act CAAA .......................................... Clean Air Act Amendments CARB .......................................... California Air Resources Board CNG ..... ................ . ... ........... .. ... ... Compressed Natural Gas CRAB .......................................... County Road Administration Board DOL ... .... ..... .......... ...................... Department of Licensing DQO ........................................... Data Quality Objectives DV ....... ....... . ...... .. .... ................. .. Design Value ECA............................................. Emission Control Area Ecology....................................... Washington State Department of Ecology EPA ......... .... ......... . .. ..... .. ............. U.S. Environmental Protection Agency FEM ............................................ Federal Equivalent Method FR ........ .... .................... .... ........... Federal Register FRM ............................................ Federal Reference Method FTA ........................ ...... ... .... ...... .. Federal Transit Administration GIS .............. ............................. ... Geographic Information Systems g/hr ............................................ grams per hour HPMS ......................................... U.S. DOT Highway Performance Monitoring System IPP/QAP .................................... Inventory Preparation Plan and Quality Assurance Plan LMP .... .. .... .... ... ............ ....... ....... Limited Maintenance Plan MA ...... ..... .. ....... ................. ........ Maintenance Area MOS .......................................... Margin of Safety MOVES ............... .. ...... .. ..... ... ...... Motor Vehicle Emission Simulator NAA ............................................ Nonattainment area NAAQS ................. ....... ....... ........ National Ambient Air Quality Standards NAMS ..................... ... ................. National Ambient Monitoring Sites viiNEI ... .. .... ..... ... ......... . ............. . .. .. EPA's National Emission Inventory NESHAP ..... ............................... .. National Emission Standards for Hazardous Air Pollutants NRLM .. .... ..... .... .. ...... ...... .. .... ... ... Non-Road, Locomotive, and Marine NSPS ........................................... New Source Performance Standards OLS .......... ............ .. ....... ..... .... .. ... Ordinary Least Squares ODEQ ......................................... Oregon Department of Environmental Quality OSPI ...... ..................................... Office of the Superintendent of Public Instruction PS.

CAA ........................................ Puget Sound Clean Air Agency PM 10 ........................................... Particulate Matter, ten microns or less PM 2.5 .................. .................. ...... Particulate Matter, 2.5 microns or less RACM ......................................... Reasonably Available Control Technologies RWC .......................................... Residential Wood Combustion SIP ............................................. State Implementation Plan SLAMS .. .... ............................ ..... State and Local Ambient Monitoring Sites TCMA ......................................... Thurston County Maintenance Area TRPC .......................................... Thurston Regional Planning Council TEOM ......................................... Tapered Element Oscillating Microbalance TSP .............................. .... .......... . Total Suspended Particulate ULSD ................ .... .. .................... Ultra Low Sulfur Diesel UP .................................... .. .... .... Union Pacific Railroad 

## I 3 . 

### b' 11g m .......................... .... ........... m1crograms per cu 1c meter VMT ........................................... Vehicle Miles Traveled WRAP ............ ........................ .. ... Western Regional Air Partnership WSDOT ...................................... Washington State Department of Transportation

viii

## Executive Summary EPA analysis- the EPA's analysis is contained in the detailed sections, so there are no comments on the executive summary or introductory text . Portions of Kent and the industrial areas of the Duwamish Valley in Seattle and the Tideflats ofTacoma meet the federal24-hour standard for particulate matter 10 micrometers and smaller (PM10). This State Implementation Plan (SIP) revision explains how these areas will continue to meet the standard through 2020. The Environmental Protection Agency (EPA) sets air quality standards for particulate matter to protect public health. Particulate pollution is classified by its size, PM10 is considered coarse particulate matter and PM2.5 is considered fine particulate matter. Particles less than 10 micrometers can penetrate into the lungs and cause short and long-term health problems. There are separate 24-hour standards for PM10 (150 j..lg/m3) and PM2.5 (35 j..lg/m3) because particle size is directly linked to their potential for causing health problems. These three areas were classified as nonattainment areas in 1990 by the Environmental Protection Agency (EPA) for the 24-hour PM10 National Ambient Air Quality Standard (NAAQS). The Kent, Seattle, and Tacoma PM10 nonattainment areas were reclassified to maintenance areas in 1993, 1995, and 1995, respectively. The Clean Air Act (CAA) requires a two 10-year maintenance plans for the three areas, the first 10-year maintenance plan was submitted to the EPA in 1997. This plan is the second and final10-year maintenance plan and fulfills the CAA requirement. The Kent, Seattle, and Tacoma PM10 maintenance areas are currently well below the 24-hour NAAQS for PM10. Compliance with this standard is maintained if PM10 values do not exceed 150 j..lg/m3 more than once a year, on average, over three years . The areas qualify to submit a streamlined Limited Maintenance Plan (LMP) because the 5-year Design Values for these areas do not exceeded 98 j..lg/m3 -a screening threshold- and meet other criteria. LMPs are for areas that show little risk of re-violating the PM10 NAAQS . PM10 concentrations are estimated using the historic relationship between PM10 and PM2.5 described in Section 4. PSCAA will continue to operate ambient PM2.5 monitors in all three maintenance areas . Three-year design values from PM10 concentrations for the three maintenance areas will be estimated annually to verify continued attainment of the NAAQS . Five year design values will be calculated to verify continuing qualification for the LMP option . Direct PM10 monitoring will be reestablished if calculated PM10 design values reach 98 j..lg/m3, the LMP option screening threshold . The control and contingency measures from the attainment and maintenance plans are still in place. All existing PM10 control measures will continue in the region and are described in Section 6. Primary control strategies include a residential wood smoke control program, fugitive dust ·program, and a 9prohibition on outdoor burning. PSCAA's Regulation 1- Article 13 .07 (b) provides for prohibition of the use of uncertified woodstoves for the sole purpose of meeting CAA requirements for contingency measures. The contingency measure will be triggered if the estimated PM10 concentrations violate the PM10 NAAQS at the maintenance area monitors. 

## 1. Introduction This State Implementation Plan (SIP) revision explains how the PM 10 maintenance areas of Kent, Seattle, and Tacoma currently meet and will continue to meet the 1987 National Ambient Air Quality Standard (NAAQS) for particulate matter ten microns or smaller (PM 10) through 2020. Puget Sound Clean Air Agency (PSCAA) prepared this plan with the Wash ington State Department of Ecology (Ecology). PSCAA is the local clean air agency with jurisdiction over the Kent and Seattle maintenance areas in King County and the Tacoma maintenance area in Pierce County. 

### Particulate Matter Standards The Environmental Protection Agency (EPA) sets air quality standards for particulate matter to protect public health. Particulate matter pollution is a public health issue because smaller particles can penetrate deep into the lungs and cause health problems. Particulate matter comes from soot, dust, unburned fuel suspended in the air, and can also be formed in the air from chemical reactions involving gaseous precursors. EPA revised the particulate matter NAAQS from total suspended particulate (TSP) to PM 10 on July 1, 1987, since smaller particles were determined to be more harmful. The primary health-based 24-hour standard for PM 10 is 150 llg/m 3, and cannot be exceeded more than once a year on average over three years. A 24-hour standard for fine particulate matter 2.5 microns or smaller (PM 2.5) was set to 65 11g/m 3 on July 18, 1997, and was revised to 35 11g/m 3 in 2006 . 

### Maintenance Area Compliance History EPA analysis- the EPA verified that the dates, citations, and summaries of the original attainment plans and the 1 51 10-year maintenance plan are correct.

The Kent, Seattle, and Tacoma PM 10 maintenance areas were designated Group 1 PM 10 areas in 1987 by the Environmental Protection Agency (EPA) for having a greater than 95% probability of violating the 24- hour PM 10 standard. These areas were then classified as nonattainment areas in 1990 as required for Group I areas by the 1990 Amendments to the Clean Air Act (CAA) . The PM 10 attainment plan for Kent was fully approved by EPA on July 27, 1993 (58 FR 40059) and the plans for Tacoma and Seattle were fully approved by EPA on October 25, 1995 and October 26, 1995, respectively (60 FR 54599 and 60 FR 54812). EPA approved the first 10-year maintenance plan on March 13, 2001 (66 FR 14492). This second 10-year maintenance plan is a Limited Maintenance Plan (LMP) and demonstrates continued attainment of the NAAQS through 2020 at existing PM 2.5 monitors in the Puget Sound region . PM 10 concentrations will be estimated using the relationship between PM 10 and PM 2.5 described in 10

### Section 4. All existing PM 10 

### control measures will be continued in the region and are described in Section 

### 6. Primary control strategies included in the PM 10 

### attainment and maintenance plans for the three areas included a residential wood smoke control program , a fugitive dust program , and a prohibition on opening burning, and industrial emission controls . The control and contingency measures from the attainment and maintenance plans are still in place . PSCAA' s Regulation I- Article 13 .07 (b) provides for prohibition of the use of uncertified woodstoves for the sole purpose of meeting CAA requirements for contingency measures. The contingency measure will be triggered if the estimated PM 10 

### concentrations violate the PM 10 

### NAAQS at the maintenance area monitor based on nephelometer and/or FEM monitoring of PM 2 .s· PSCAA will .continue to operate ambient PM 2 .5 

### monitors in all three maintenance areas . PM 10 

### concentrations will be estimated based on these measurements and the values will be evaluated annually to verify continued attainment of the NAAQS. PM 10 

### monitoring will be reinst ituted if calculated design values reach 98 11g/m 3

. 

### If air quality degrades significantly or if there are significant changes in any of the assumptions of this LMP, PSCAA will re-evaluate the plan . 

### Plan Structure This SIP revision includes the compliance history for Kent, Seattle, and Tacoma and describes how the areas met and will continue to meet the standard, as well as what will be done if an area violates the NAAQS . This plan also includes other EPA-required elements, such as an emissions and monitoring review and public process requirements. This document is organized as follows : 

### Section 2 -Background - describes the area's compliance history and contains background information on the PM 10 

### standard 

### Section 3- Lim ited Maintenance Plan (LMP) Option- describes the criteria an area must meet to qualify for this option and how the three maintenance areas meet these criteria 

### Section 4- PM 10 

### Monitoring History - provides a brief history of monitoring in the three maintenance areas, an evaluation of the relationship of PM 10 

### to PM 2 .5 

### and justification for using an alternative monitoring method 

### Section 5- Emission Inventory- includes historical information on the most significant PM 10 

### emission categories from the original maintenance plan and an updated inventory on these categories 

### Section 6- Control Measures - lists the measures and rules that were in place in the original maintenance plan and the current rules that maintain and enforce these measures 

### Section 7- Contingency Measures - describes the provisions that are in place in rules and will be taken , ifthe PM 10 

### standard is violated

11

### Section 8- Commitment to Continued Monitoring and Verification of Continued Attainmentdescribes how monitoring will be continued and how compliance will be confirmed 

### Section 9- Summary of Maintenance Plan Commitments- outlines commitments of this plan 

### Section 10- Completion of Required Plans- states that this document fulfills federal planning requirements 

## 2. Background Geographic Area

EPA analysis- a portion ofthe Tacoma maintenance area is within the Puyallup Indian Reservation. In 1991, the Puyallup Indian Tribe and PSCAA entered into an agreement to cooperatively manage air quality in the overall airshed, including PSCAA providing technical assistance when appropriate. The technical demonstrations contained in this plan for meeting Clean Air Act 175A maintenance plan requirements such as the demonstration of attainment, the calculation of motor vehicle regional emissions, the quantification of inventories, and the assurance of adequate monitoring cover the entire geographic span of the Tacoma maintenance area, including all Tribal lands . The only exception is the set of state and local control measures cited in this plan which are not approved to apply on trust lands within the exterior boundaries of the Puyallup Indian Reservation, in accordance with the Puyallup Tribe ofIndians SettlementAct of 1989, 

### 25 U.S .C. 1773 . The EPA and the Puyallup Tribe of Indians are responsible for control measures on trust lands as discussed in the final rule Federal Implementation Plans Under the Clean AirActfor Indian Reservations in Idaho, Oregon and Washington, 

### also called the FARR (April 8, 2005,70 FR 18074). reviewed the FARRand determined that the existing control measures on trust land are adequate to ensure continued maintenance of the PM 10 

### standard and satisfy the remaining Clean Air Act 175A requirements. The EPA sent an offer for consultation on review of the Kent, Seattle, and Tacoma PM 10 

### plan on October 18, 2013 . Unlike ozone nonattainment areas which tend to have a large geographic scale due to the nature of ozone secondary formation, the boundaries of the Kent and Seattle PM 10 

### maintenance areas are more localized and do not include other federally recognized Tribal reservations .

The Kent PM 10 

### maintenance area is located on the eastern side of the Green River Valley between the Cities ofTukwila and Auburn. The PM 10 

### sources in this region come from residential wood burning, light industry, and mobile sources. The valley floor is roughly two to three miles in width and is bound by hills which rise 300-400 ft . in elevation. These hills act to trap pollutants under stable meteorological conditions (inversions). These conditions exist most frequently during the late fall and winter and are associated with the majority of particulate matter violations . 12

### Figure 2.1 , below, shows the Kent PM 10 

### maintenance area boundary and the location of the monitoring site. The Seattle PM 10 

### maintenance area is comprised of the Duwamish industrial and commercial area immediately south of the downtown district and includes the Port of Seattle . The monitoring site has been in place since 1971 and is located in the center of the Duwamish industrial valley near the Port of Seattle . The site is a neighborhood scale site that is representative of South Seattle neighborhoods and ambient exposure in the industrial valley. The site is influenced by a very complex mixture of mobile sources, port and marine sources, industrial sources, winter home heating wood smoke, and other pollution sources. The site is 80 meters west of E. Marginal Way, which is a main arterial for many large haul trucks, as well as service vehicles and personal automobiles. Figure 2.2 shows the Seattle maintenance area boundary, the areas of the Port of Seattle that lie within the maintenance area , and the air monitoring station . The Tacoma PM 10 

### maintenance area is comprised of the industrial area ofTacoma , including the Port of Tacoma , a Kraft pulp mill and other industrial operations. The monitoring site has been in place since 1987 in the industrial area near the Port of Tacoma . The site is neighborhood scale located near several industrial air pollution sources . The sources that impact the area are a mixture of mobile sources, port and marine sources, industrial sources, and winter home heating from wood burning. The site is also within the Puyallup Indian Reservation , as well as the 2006 PM 4 .5

### Tacoma- Pierce County nonattainment area . Figure 2.3 shows the Tacoma maintenance area boundary, the Port ofTacoma , and the location of the monitoring site .

13

### Figure 2.1: The Kent, WA PMto Maintenance Area ! l 4 t • • i . 

## Kent PM 10 

## Maintenance Area #/ ·t**·-~** 

## [ I 

# \ •..,...-, I I I 

# (



# * AJr Monitoring Station 0 lndustnal Registered Sources Repcrnng PM :: 1n 2011 Highwa ys and MaJ or Roads MaJor Freeways ···-··• Rail 

### c:::::::J F't.h Maintenance Area



### 14 ' ·' I t ;I



### +**~** .1

## ~ l i 

# r**~**

.:, 1**~ ~** **~** 

# i ' 0 0.2 0.4 

# - - 0**~** p s cleanai r. org Puget $ound ·**~)** ;;.: Ag· HIC\' 0.8 1.2 Miles

### Figure 2.2: The Seattle, WA PMto Maintenance area / 

## Seattle PM 1

## 6':Maintenance Area**'<,~·, -.**  ., . "'

,,/



# L 

# * Air Momtonng Station 0 Industrial Registered Sources Reporting P!Vkin 2011 Highways and Ma1or Roads Major Free'h ays

............., Ra1 l 

## EZ23 Port 

## CJ Pf'lhMa111tenance Area

15 

# •**~** o . ;_ '**~"------** pscleandir.org Puga: Sc.undC:t::' ....**i· .;.~enc** **y** 2 

# I ,. Miles ..

### Figure 2.3: The Tacoma, WA 

### PM10 maintenance area 

# Tacoma PM 10 

# Maintenance Area



# * Air Monitonng Stat1on 0 Industrial Registered Sources Reporbng Pf\'hin 2011 Highways and MaJor Roads Major Freeway s ·-'·······+ Ra1l 

## CZJ Pcrt Puya l up Indian Rese N ation 

## CJ Pf\'kMaintenanceArea



### 16 '7

''"...:_.___j

### ---~~ psc:leandi r.org P1.19c:**Soun~** .:h::' ."':i · .:O.;JEncr

# ~ o . :.. 0.8 1.6 

## I Miles

### Compliance History EPA analysis- this historical summary is consistent with our records. On August 7, 1987, EPA identified Kent and the industrial areas of Seattle and Tacoma as having greater than 95% probability of violating the 24-hour PM 10 average standard. By operation of law, all three areas were designated moderate PM 10 nonattainment areas upon enactment of the CAA on November 15, 1990. State Implementation Plan (SIP) submittals addressing PM 10 nonattainment in Kent and Seattle were submitted by Ecology to EPA in November 1990, followed by the submittal for Tacoma one year later. The principal control strategies included in the PM 10 attainment plans for the three areas included a residential wood smoke control program, a fugitive dust control program , and a prohib ition on outdoor burning. The PM 10 attainment plan for Kent was fully approved by EPA on July 27, 1993 (58 FR 40059) and the plans for Tacoma and Seattle were fully approved by EPA on October 25 , 1995 and October 26, 1995, respectively (60 FR 54599 and 60 FR 54812) . The maintenance plan and request for redesignation from nonattainment to maintenance for Kent, Seattle, and Tacoma were app roved on March 13, 2001 (66 FR 14492) . This plan is the Second 10-Year Limited Maintenance Plan for PM 10 in Kent, Seattle, and Tacoma and is the last maintenance plan for these areas . This maintenance plan revision ensures comp liance through 2020 and fulfills the second 10-year planning requirement of CAA Section 175A (b). 

## 3. Limited Maintenance Plan Option EPA analysis- early in the process PSCAA worked with the EPA and Ecology to review preliminary data and discuss the qualification criteria . As a result of those discussions, the EPA recommended the limited maintenance plan option . In consultation with Ecology and EPA, PSCAA chose to follow the EPA's Limited Maintenance Plan (LMP) option for the second PM 10 maintenance plan for the Kent, Seattle, and Tacoma maintenance areas . The EPA developed the Limited Maintenance Plan (LMP) option for areas with little risk of re-violating the PM 10 standard . EPA allows states to use this policy to prepare the required second 10-year maintenance plans, if the area meets the qualification criteria in the EPA LMP Option Guidance (LMP Guidance) 1

. The LMP option for moderate PM 10 nonattainment areas requires an area to meet certain applicability criteria in order to qualify for the LPM option . The first criterion is that an area should be attaining the 1 Limited M aintena nce Pl an Option for M oderate PMlO Nonattai nment Areas 17National Ambient Air Quality Standard (NAAQS), the second that the average PM 10 design value based on the most recent 5 years of air quality data should be at or below 981Jg/m 3 for the 24-hour PM 10 NAAQS2• The third criterion is that the area should expect only limited growth in on-road motor vehicle emissions and pass a motor vehicle regional emissions analysis test. The Kent, Seattle, and Tacoma maintenance areas meet these criteria as described below; supporting information can be found in Appendix A. 

### NAAQS Qualification Criterion EPA Analysis- Robert Kotchenruther worked closely with PSCAA in developing the attainment analysis and PM 10 concentration estimates described below. All three areas are well below the 24-hour NAAQS of 150 1Jg/m 3 with estimated PM 10 concentrations of 44±3 1Jg/m3 for Kent, 49±4 1Jg/m 3 for Seattle, and 55±5 1Jg/m 3 for Tacoma. To qualify for the LMP option , the area must be attaining the 24-hour NAAQS, 150 1Jg/m 3

. Monitoring data shows that Kent, Seattle, and Tacoma have been in attainment of the standard since 1987, 1990, and 1989 respectively. The areas were reclassified to attainment for the 24-hour PM 10 standard in March 2001 when EPA approved the first 10-year maintenance plan for Kent, Seattle, and Tacoma. Table 3. 1 below shows the 3-year design values are well below the 24- hour NAAQS of 150 1Jg/m 3 for all three PM 10 maintenance areas. Table 3.1: Three-year design values calculated usingthe most recent three years of estimated 

### PM1o concentrations Site YEARS NO. DATA TABLE LOOK- STATISTICAL POINTS UP,I-lg/m 3 FIT, l-lg/m 3 Kent 2010-2012 1017 44 44±3 Seattle 2010 - 2012 1068 48 49±4 Tacoma 2010 - 2012 1030 59 55±5

2 Limited Maintenance Plan Option for Moderate PMlO Nonattainment Areas , pp 3 

### 18

### Design Value Criterion EPA analysis- the general approach of this plan is consistent with PM 10 

### estimation methodology recently approved in the Thurston County PM 10 

### action. The methodology is technically sound and the estimated five-year PM 10 

### concentrations are well below the limited maintenance plan qualification threshold of 98 11g/m 3

. 

### For the 2008 to 2012 period, estimated PM 10 

### concentrations were 46±3 11g/m 3 

### for Kent, 50±5 11g/m 3 

### for Seattle, and 58±8 11g/m 3 

### for Tacoma. (Note: PSCAA made a minor typographical error in the narrative ofthis section. The correct 2008 to 2012 value for Seattle should be '50±5 11g/m 3 

### rather than 48±5 11g/m 3 

### to match Table 3.3. Since this is a minor typographical error, PSCAA will probably correct this prior to final submission to the EPA). To qualify for the LMP option, the average 24-hour PM 10 

### design value for the area based upon the most recent five years of data should not exceed 98 11g/m 3

. 

### A design value is the statistic based on monitoring data that determines an area's compliance status. The LMP Guidance directs the design value be based on the most recent five years of data. The design values for Kent, Seattle, and Tacoma based on Federal Equivalence Method (FEM) 24-hour PM 10 

### monitoring data from 2003 through 2007 are 57±3 11g/m 3, 

### 68±41-lg/m 3, 

### and 72±9 11g/m 3

. 

### The most recent design values estimated based on an alternative method, using 2008 to 2012 values, are 46±3 11g/m 3, 

### 48±5 11g/m 3, 

### and 58±8 11g/m 3 

### respectively. All of these values are below the 98 11g/m 3 

### value stipulated in the LMP Guidance. The PM 10 

### SIP Development Guideline 3 

### (SIP Guideline) outlines the following four approaches to determine the PM 10 

### design value: a table look-up procedure; fitting a statistical distribution to several years of data; a graphical estimation technique; and the use of a conditional probability approach. This analysis uses both the table look-up method and a statistical fit to calculate the PM 10 

### design values. The graphical estimation and the conditional analysis were considered for this analysis however the table look-up method and the statistical fit were the most appropriate for the Kent, Seattle, and Tacoma monitoring datasets. The graphical estimation technique was not used in this analysis due to insufficient data in some cases. Where there was insufficient data the concentration that corresponds to a frequency of 1/365 could not be read directly off a graph of the distribution at each of the sites for all of the 5-year time periods. The conditional probability approach is used in cases where individual years of data should be treated separately. Preliminary analysis of the conditional probability approach showed that values for individual years did not vary significantly from year to year. Calculating the design value using the table look-up method and the statistical fit method allows for the most conservative design value to be selected . The table look-up procedure is outlined in the PM 10 

### SIP development guide4

. 

### The PM 10 

### SIP development guide states that the design concentration for PM 10 

### is the concentration that corresponds to a frequency

3 PM-10 SIP Development Guideline, publication EPA 450/2 86-001 4 PM-10 SIP Development Guideline, publication EPA 450/2 86-001, Table 6-1, pp.6-5 

### 19of 

### 1/365 on an emp i rical frequency distribution .4 Table 

### 3 .2 below is used to estimate which point on the empirical frequency distribution corresponds to a frequency of 

### 1/365 . 

### Table 3.2: 

### Tabular Estimation ofPM10 Design Values4 Number of Values Data Point to be Used 

### 1 -347 Highest Value 

### 348-695 Second Highest Value 

### 696 - 1042 Third Highest Value 

### 1043 - 1390 Fourth Highest Va l ue The statistical fit is calculated according to the approach is outlined on pages 

### 18-20 of the Ozone guidel i ne 5

. The design value is calculated by solving for the concentration of PM 10 that is equal to a probabil ity of 

### 1/3654. The 

### 95 % confidence interval is reported with the statistical fit design va l ue . The design values calculated using with the table look-up method all fall within the range of the 

### 95% confidence interval of the statistical fit design values . Design values for the most recent 5 years of monitoring data are shown in bold in Table 

### 3 .3 alongside design values calculated using estimated PM 10 concentrations . Mon itoring data is discussed in Section 

### 4 . 1 and PM 10 estimates are discussed in Section 

### 4.2. 

### Table 3.3: 

### Five-Year Design Values for Kent, Seattle, and Tacoma 5-VEAR 5-VEAR 5-VEAR 5-VEAR PERIOD DESIGN VALUE DESIGN VALUE Site YEARS NO . DATA TABLE LOOK- STATISTICAL POINTS UP, 11g/m 3 FIT, 11g/m3 Kent 

### 2003-2007 1149 58 57±3 Kent 

### 2008-2012 1762 43 46±3 Seattle 

### 2003-2007 1318 69 68±4 Seattle 

### 2008-2012 1311 

# so 50±5

5 Guideline fo r the Interpretation of Ozon e Air Quality S tan dards, EPA-450/4-79-003 20Tacoma 

### 2001-2007* 900 68 

### 72±9 Tacoma 2008 - 2012 1725 54 58±8 * 2004 was excluded because more than 75% of the data was missing 

## Motor Vehicle Regional Analysis Criterion EPA analysis- estimated growth in on-road motor vehicle PM 10 emissions is very small during the ten year period . Total estimated growth is shown in the equations below as VMTp; x DVmv,and calculates to 1.5 11g/m 3 for Kent, 2 .7 11g/m 3 for Seattle, and 2 .9 11g/m 3 for Tacoma over the entire ten -year period . All three areas easily meet the margin of safety of 98 11g/m 3, with Kent= 61.5 11g/m 3, Seattle= 74 .7 11g/m 3 , and Tacoma= 83 .9 11g/m 3

. To qualify for the PM 10 LMP option , an area should expect only limited growth in on -road motor vehicle PM 10 emissions (including fugitive dust) and pass a motor vehicle regional emissions analys is test, found in Appendix B of the LMP Guidance. The results of the analysis must be less than 98 11g/m 3 , the Margin of Safety (MOS) value for the 24-hour PM 10 standard. The Kent, Seattle, and Tacoma maintenance areas meet both these criteria, as described below and in Appendix A. The following methodology was used to determine whether increased emissions from on-road mobile sources could , in the next 10 years, increase concentrations in the maintenance areas and threaten the assumption of maintenance that underlies the LMP Guidance . DV + (VMTp; x DVm v

l 

### < MOS Where : DV =the area's design value based on the most recent 5 years of data in 11g/m 3 VMTp; =the projected percent increase in vehicle miles traveled (VMT) over the next 10 years DVmv = motor vehicle design value based on on -road mobile portion of the attainment year inventory in 11g/m 3 MOS =margin of safety for the relevant PM 10 standard for a given area: 40 11g/m 3 for the annual standard or 98 11g/m 3 for the 24-hour standard 

### Qualification for the LMP 

### approach is demonstrated when the motor vehicle regional a value less than the MOS 

### of98J.1.g/m3 

### for the 24-hour PMto 

### standard. The variables and equation for each ofthe three maintenance areas are shown in 21Table 3.4 . The results of the calculation is less than the MOS of 98 1-1g/m 3 and therefore demonstrates that the Kent, Seattle, and Tacoma PM 10 maintenance areas pass the motor vehicle regional analysis and qualify for the LMP approach . 

### Table 3.4: Margin ofSafety Comparison Kent Seattle Tacoma DV (llg/m 3 ) 60 72 81 VMTp; 9% 11 % 12% DVmv (llg/m 3 } 16 .8 24.5 24 .3 DV + (VMTp; x DVmv) 61.5 74 .7 83 .9 MOS (llg/m 3 ) 98 98 98 

### LMP 

### Qualification EPA analysis -- The EPA concurs with PSCAA/Ecology's demonstration that the three areas meet the qualification criteria outlined in the limited maintenance plan memo. The EPA is also proposing to approve the monitoring system modification, using PM 2.5 monitoring data to estimate PM 10 concentrations, under 40 CFR 58 .14(c) for the second 10-year ma intenance plan period similar to the previously approved Thurston County PM 10 action . PSCAA has demonstrated that this estimation method is a reproducible approach to representing air quality in all three maintenance areas, and all three areas continue to meet the applicable Appendix D requirements evaluated as part of the annual network approval process . The Kent, Seattle, and Tacoma PM 10 maintenance areas meet the LMP qual ification criteria and qualify for the LMP option . As described above and in Appendix A, these areas are in compliance with the 24- hour NAAQS for PM 10, the five year design values are well below 981-lg/m 3 and the growth in PM 10 emissions from motor vehicles will not threaten compliance with the standard . PSCAA provided its analysis to Ecology and EPA Region 10 office. EPA Region 10 and Ecology mutually agreed to the LMP approach. We have discussed the alternative approach for PM 10 estimation, outlined in Section 4 .2, with Ecology and EPA. With this submittal , we request approval for the alternative approach for PM 10 estimation . PSCAA will calculate the 3-year and 5-year PM 10 design value estimates and provide them to Ecology annually. Ecology will include a statement that the area continues to qualify for the LMP option in the annual monitoring network report . The report can be found at https://fortress.wa .gov

### Iecy/pubIications/U IPages/Home .aspx

22

## 4. Particulate Matter Monitoring EPA analysis-**t~is** section outlines the monitoring history and technical basis for the PM 2.5 and PM 10 correlation. This analysis was thoroughly reviewed by EPA Region 10. 

## 4.1. PMto Concentrations Kent Maintenance Area The daily (midnight to midnight) concentrations of PM 10 and PM 2.5 are shown in Figure 4.1.1. PM 10 monitored values are shown from 1987 through 2007 (blue circles), PM 2.5 monitored values are shown from 1999 through 2012 (green plus), and estimated PM 10 values based on PM 2.5 monitored values are shown from 1999 through 2012 (black dots). Monitored concentrations have never exceeded the NAAQS since monitoring began in 1987 . The maximum 24-hour concentration recorded during the last five years of PM 10 FEM monitoring was 69 11g/m 3 in 2006. Estimated PM 10 concentrations are shown in black, the highest estimated PM 10 concentration is 144 11g/m 3, this value occurred on July 4, 2009 . Estimated concentrations of PM 10 are shown in the figure below (black dots). Model development is described in Section 4.3. 

### Figure 4.1.1: Kent Historical PMto 

### Concentrations Kent 24-hour PM 10 Concentrations**250r----~----,-----,----~--~==~======~** 200 150 0 0 0



### 23 o PM 10 "' PM2.5 • Estimated PM 10

-- NAAQS

### Kent Monitoring The Kent PM 10 maintenance area is shown in Figure 

### 4 . 1.1 . PSCAA monitored PM 10 at James Street and Central Avenue using a Federal Reference Method (FRM) between 

### 1988 and 

### 2003 and a Federal Equivalent Method (FEM) from July 

### 2004 through December 

### 2007. The area has been in compliance with the standard since 

### 1987 . Federal Equivalent Method (FEM) PM 10 values were low enough that the FEM monitor was removed with EPA approval at the end of 

### 2007. Excerpts from this report are included as Appendix B. Since then, continuous monitoring of PM 2.5 has been conducted in Kent with a TEOM, which has been correlated with a co-located PM 10 monitor to provide estimated PM 10 values. Figure 

### 4 . 1.2 shows the dates and monitors located at the Central and James Street monitoring site from 

### 1988-2007. All of the data used to develop the relationship between PM 10 and PM 2.5 relied exclusively on data downloaded from EPA's Air Quality System (AQS) . The data downloaded from AQS was collected using the monitors show in Figure SS. The model described in section 

### 4.2 was developed using data from the time period where PM 10 and PM 2.5 measurements are co -located 

### {1999-2003). For the period 

### 2008- present the PM 10 concentrations are estimated using PM 2.5 concentrations measured with the instruments in Figure 

### 4.1 .3. Details on the PM 10 and PM 2.5 relationship are described in section 

### 4.2. 

### Figure 4.1.2: PM10 

### and PMz.s 

### data used to develop the PMto 

### to PMz.s 

### relationship

Kent PM2.5 • Partisol R&P Model2025

Kent PM10 ·Hi Voi/GMW· 1200

Kent PM 10 • R&P TEOM 1400

1/1/1985 1/1/1988 1/1/1991 1/1/1994 1/1/1997 1/2/2000 1/1/2003 1/1/2006

24

### Figure 4.1.3: PMz.s 

### monitoring data used to estimate PM1o 

### concentrations from 2008-present

Kent PM2.5- R&P TEOM FEM

Kent PM2 .5- R&P TEOM FDMS_STP

Kent PM2 .5- R&P TEOM 1400

1/1/2008 12/31/2008 12/31/2009 12/31/2010 1/1/2012 12/31/2012 12/31/2013

25

### Seattle Maintenance Area The 24-hour concentrations of PM 10 and PM 2.5 are shown in Figure 4. 1.4 below. PM w monitored values are shown from 1985 through 2007 (blue circles), PM 2.5 monitored values are shown from 1999 through 2012 (green plus), and estimated PM 10 values based on PM 2.5 monitored values are shown from 1999 through 2012 (black dots). Monitored concentrations have not exceeded the NAAQS since 1990. The maximum 24-hour concentration recorded during the last five years of FEM monitoring was 80 11g/m 3 in 2006 .



### Seattle MonitoringFigure 4.1.4: Seattle Historical PMto 

### Concentrations

0 0 0 0

Jan90 Seattle 24·hour PM 10 Concentrations

0 II

Jan95 0 0 0 0 o PM 10 .-**PM ~**  Estimated PM 10

- NAAQS

Jan15

The Seattle PM 10 maintenance area is shown in Figure 2.2 . PSCAA monitored PM 10 at both 4401 and 4752 East Marginal Way South using an FRM between June 1988 and December 2003 and an FEM from October 2004 through 2007 . The area has been in compliance with the standard since 1990. Federal Equivalent Method (FEM) PM 10 values were low enough that the monitor was removed with EPA approval at the end of 2007. Excerpts from this report are included as Appendix B. Since then, continuous, reference and non-reference method monitoring of PM 2.5 has been conducted at the Seattle monitoring site and correlated with a co-located PM 10 monitor to provide estimated PM 10 values .. Figure 4.1.5 shows the dates and monitors located at the 4401 and 4752 East Marginal Way South monitoring site from 1985-2007. All of the data used to develop the relationship between PM 10 and PM 2.5 relied exclusively on data downloaded from EPA's Air Quality System (AQS) . The data downloaded from AQS was collected using the monitors show in Figure 4.1.5. The model described in section 4.2 was developed using data from the time period where PM 10 and PM 2.5 measurements are co-located (1999- 2007) . For the period 2008- present the PM 10 concentrations are estimated using PM 2.5 concentrations measured with the instruments in Figure 4.1.6. Details on the PM 10 and PM 2.5 relationship are described in section 4.2. 

### 26

### Figure 4.1.5: PMto 

### and PMz.s 

### data used to develop the PMto 

### to PMz.s 

### relationship

Seattle PM2.S- R&P Model 202S

Seattle PM10- Hi Vol SA321A

Seattle PM10- Hi Voi/GMW-1200

Seattle PM 10- R&P TEOM 1400

1/1/198S 1/1/1988 1/1/1991 1/1/1994 1/1/1997 1/2/2000 1/1/2003 1/1/2006 

### Figure 4.1.6: PMz.s 

### monitoring data used to estimate PM1o 

### concentrations from 2008-present

Seattle PM2 .S- R&P Model2025

Seattle PM2.5 - STP Thermo Scientific 1400a & SSOOCFDMS

Seattle PM2.5- FEM Thermo Scientific 1400a & 8500C FDMS ·· ························· ---

1/1/2008 12/31/2008 1/1/2010 l

1/1/2011 1/2/2012 1/1/2013



### 27

### Tacoma Maintenance Area The 24- hour concentrations of PM 10 and PM 2.5 are shown in Figure 4. 1 .7 below. PM 10 monitored values are shown from 1987 through 2007 (blue circles), PM 2.5 monitored values are shown from 1999 through 2012 (green plus), and estimated PM 10 values based on PM 2.5 monitored values are shown from 1999 through 2012 (black dots) . Monitored concentrations have not exceeded the NAAQS since 1988. The maximum 24-hour concentration recorded during the last five years of FEM monitoring was 69 11g/m 3 in 2006 .

250 0 200 150 0 

### Figure 4.1.7: Tacoma Historical PMto Concentrations Tacoma 24-hour PM 10 Concentrations o PM 10 

### * PM2.5 Estimated PM 10

-- NAAQS

M 0 0

E 0 Cl :I 100

Jan15 

### Tacoma Monitoring The Tacoma PM 10 maintenance area is shown in Error! Reference source not found . . PSCAA monitored M 10 at 2301 Alexander Avenue site in Tacoma , Washington . The area has been in compliance with the standard since 1990. Federal Equivalent Method (FEM) PM 10 values were low enough that the monitor was removed with EPA approval at the end of 2007 . Excerpts from th is report are included as Appendix B. Since then continuous monitoring of PM 2.5 has been conducted at the Tacoma monitoring site and correlated with a co-located PM 10 monitor to provide estimated PM 10 values. Figure 4.1.8 shows the dates and monitors located at the 2301 Alexander Avenue monitoring site from 1988-2007. All of the data used to develop the relationship between PM 10 and PM 2.5 rel ied exclusively on data downloaded from EPA's Air Quality System (AQS). The data downloaded from AQS was collected using the monitors show in Figure 4.1.8. The model described in section 4.2 was developed using data from the time period where PM 10 and PM 2

### .s measurements are co-located (1999-2003) . For the period 2008- present the PM 10 concentrations are estimated directly from a correlated nephelometer. The nephelometer is the only instrument presently reporting PM 2.5 concentrations at the Alexander Avenue monitoring site.



### 28Nephelometers have been used to monitor particulate matter light scatter in the maintenance areas for decades . A nephelometer measures light scatter (bscat) and, when correlated with a Federal Reference Method (FRM) instrument, accurately represents particulate matter levels. Because of the high correlation between nephelometer readings and FRM and Federal Equivalent Method (FEM) monitors, Ecology and PSCAA conclude that PM 2.5 values calculated directly from a nephelometer are sufficiently reliable and reproducible. Nephelometer measurements began in the maintenance areas in 1999 and measurements continue in those areas today . Each of the monitoring stations in the three maintenance areas measure PM 2.5 with a nephelometer. The Seattle and Kent monitoring stations currently both use a FEM method and a nephelometer. PM 2.5 measurements reported using the FEM monitoring and the nephelometer the Seattle and Kent maintenance areas are well correlated. Details on the PM 10 and PM 2.5 relationship are described in Section 4.2. 

### Figure 4.1.8: Tacoma monitoring data used to calculate the PM10 

### PMz.s 

### relationship

Tacoma PM2.5- R&P Model2025

Tacoma PM2.5- STP Thermo Scientific 1400a & 8500CFOMS

Tacoma PM10- Hi Voi/GMW-1200

Tacoma PM10- R&P TEOM 1400 1/1/1985 1/1/1988 1/1/1991 1/1/1994 1/1/1997 1/2/2000 1/1/2003 1/1/2006

29

## 4.2. Model Development EPA analysis- this modeling methodology is technically sound and Region 10 concurs with the approach. Monitoring for PM 10 

### concentrations was discontinued with EPA approval at all three monitoring stations in late 2007 because PM 10 

### levels were so low and continued attainment of the NAAQS could be ensured through correlation with PM 2

### .s monitoring. PM 10 

### concentrations from 2008 to the present are calculated using a relationship between PM 10 

### and PM 2.5 . 

### PM 2.5 

### measurements collected from 1999- 2007 were correlated to PM 10 

### measurements collected in the same period . Many of the sources of PM 10 

### are independent of season; however, residential wood burning in all three maintenance areas occurs primarily in the winter months, October-March. Due to the difference in emission sources in the winter months compared to the summer months, the relationship was calculated separately for summer months, April- September, and winter months, October- March. The relationship between PM 2.5 

### and PM 10 

### was calculated using a robust regression technique . The standard ordinary least squares (OLS) regression technique, which uses a Pearson correlation, is not suitable for data with outliers or uncertainty in the independent variable. For weaker correlations, an OLS regression will result in a slope with a significant low bias. A robust regression technique reduces the low bias on the slope6

· 1 

### and is less sensitive to outliers6

·2

. 

### For our analysis, the OLS approach resulted in a slope with a low bias for some of the maintenance areas, which underestimated the PM 10 

### concentrations . Instead , we used an iteratively re-weighted least squares algorithm (with a bi-square weighting function) to calculate the slope and intercept of the PM 10 

### to PM 2.5 

### relationship. This relationship was then used to estimate PM 10 

### concentrations using measurements of PM 2

_ 5• 

### Kent The correlation between PM 10 

### and PM 2.5 

### is strongest in the winter months, October- March. This is expected because residential wood burning accounts for most of the winter time PM 10 

### and PM 2.5 

### emissions in Kent. For the winter time period, the PM 10 

### to PM 2.5 

### relationship can be described similarly using and OLS regression or a robust regression. The summer months, April- September, have lower concentrations and a weaker relationship. Since the summer relationship has a lower correlation than the winter relationship, the robust regression technique produces a steeper slope for the PM 10 

### to PM 2.5 

### relationship than the OLS technique. For consistency we use the robust regression technique to calculate the slope and intercept to describe the relationship for both the winter and summer months . The relationships for PM 10 

### to PM 2.5 

### in the summer and winter months are shown in Figure 4.2.1. The estimated PM 10 

### values are calculated using measured PM 2.5 

### and the equation of the line for summer or winter depending on the date ofthe PM 2.5 

### measurement. In other words, all PM 10 

### concentrations

6' 1 Ayers, G. P. (2001), Comment on regression analysis of air quality data, Atmos. Environ ., 35(13), 2423-2425, doi : 10 .1016/S1352-2310(00)00527-6 6'2 Huber, P. J. Robust Statistics. Hoboken, NJ : John Wi ley & Sons, Inc. , 1981. 30

### estimated for dates from April through September use the summer slope and intercept as the PM 10 

### model. As a check for the model , PM 10 

### concentrations were estimated over the period 1999-2007 and plotted against PM 10 

### measurements from the same period . The results are shown in

31Figure 4.2.2. 

### Figure 4.2.1: Winter PM10

1999-2007 Monitoring 100 80 60 0 Kent Summer (April • Septemberl1999-2007

,/ / 

### .,.,**·~r** 40 D. 

### . /· 

# .··· 

# .... ....... ··

M

### ~

" 0 :{ D. 

## , .. n>:::..·• 20

# ~ ..... 

## -r., · 'A • •



## ..p·" 0 / 0 R2 : 0.66 robust regression 2.07x+0.29 ordinary LS 1 .4x+5.6 0

100 80 60 40 20 0 0 10 20 30 40 50 Kent Winter (October-Marchl1999-2007**o& _......~** .........

0 .,...... ,k .....**-~~** 0 ....**~**.. 0 0**_**........ o o o**cs· <b**  r-- o -R_ 2_=_0-.7-6--- ------,

### o o

### ~ •.!lt\o';;d>o o .Wei" robust regression 1 .22x+3.09 ordinary LS 1 .2x+4.3 10 20 40 50



### 32 60

60 

### Summer and to PMz.s from

at the Kent Site

### Seattle Figure 4.2.2: 

### Estimated PM1o to Measured PM1o for the years 1999-2007

80 70 60 50 

### al a; 40 "CC 

# e 0 30 

### ::t IL 20 10 Kent Estimated PM 10

b. R 2 

### =0.71 • ordinary LS 0.87x+1 .9

- - robust regression 1.0x-0.03

' 1**o~-----:"1o=----2~o----=J'='o**__**..J.4o=----s~o---6.L..o--"='7o** __ __,so PM 10 measured 

### The relationship between PM1o and PMz.s in Seattle is similar in both seasons. Because this characterized by emissions from industry and the Port ofSeattle, PM1o and PMz.s emissions more uniform throughout the year. Higher wintertime concentrations are likely a result of

inversion and stagnation events which trap pollutants near the surface. Although the OLS produces a slightly steeper slope than the robust regression technique, the PM1o model for maintenance area will use the relationship described bythe robust regression technique for with the Kent and Tacoma maintenance areas. The relationships for PM1o to PMz.s in the winter months are shown in

Figure 4.2.3 The estimated PM 10 values are calculated using measured PM 2.5 concentrations and the equation of the line for summer or winter depending on the date of the PM 2.5 measurement. In other words, all PM 10 concentrations estimated for dates from April through September were estimated using the summertime slope and intercept from the PM 10 model. As a check for the model , PM 10 concentrations were estimated over the period 1999-2007 and plotted against PM 10 measurements from the same period. The results are shown in Figure 4.2.4. 33

### Figure 4.2.3: Summer and Winter PMto to PMz.s from 1999-2007 at the Seattle Monitoring Site

100 80

M

### ~ 60

:I 0**-=:~** 40 IL 20 10 Seattle Summer (April. September) 1999-2007

.-, R2

## = 0.70

-- robust regression 1.83x+4.7 ordinary LS 2x+3.9 30 40 PM2.5 ug/m3 50 60 70 Seattle Winter (October-March) 1999-2007

20 0 0 0 0 0

0 R 2 

## = 0.64 

# .. ..·

..

## ·**~""**

- robust regression 1 .26x+8.30 ordinary LS 1.4x+7.8 30 40 PM2.5 ug/m3

34 50 60 70

## Tacoma Figure 4.2.4: 

### Estimated PM1o to Measured PM1o for the years 1999-2007

"0**~** 90 80 70 60**~** 50 0 E 

# =

40 .,... 2 c.. 30 

### Seattle Estimated PM 10

6 R2 : 0.67 • ordinary LS 0.69x+6.7 -. robust regression 0.99x+1.1**o~---1~0----2~0----3~o----~4o----~5~0----6~0----7~0----8~o--~go** 

### PM 10 

### measured

In the Tacoma maintenance area the winter correlation between 

### PM 10 

### and 

### PM 2.5 

### is stronger than the summer months. This may be explained by the residential wood smoke emissions in the Tacoma region as well as decreased road dust emissions in the wintertime . For the winter time period, the 

### PM 10 

### to 

### PM 2.5 

### relationship can be described similarly using and OLS regression or a robust regression. The summer months, April- September, have higher 

### PM 10 

### concentrations and a weaker relationship. It is likely this is a reflection of the difference in 

### PM 10 

### and 

### PM 2.5 

### emission sources in the summer'months. The 

### PM 10 

### model for the Tacoma maintenance area uses the relationship described by the robust regression technique. The relationships for 

### PM 10 

### to 

### PM 2

### .s in the summer and winter months are shown in Figure 4.2.5 The estimated 

### PM 10 

### values are calculated using measured 

### PM 2.5 

### and the equation of the line for summer or winter depending on the date of the 

### PM 2.5 

### measurement. In other words, all 

### PM 10 

### concentrations estimated for dates from April through September the summer slope and intercept are used as the 

### PM 10 

### model. As a check for the model , 

### PM 10 

### concentrations were estimated over the period 

### 1999-2007 and plotted against 

### PM 10 

### measurements from the same period. The results are shown in Figure 4.2.6.

35

### Figure 4.2.5: Summer and Winter PMto to PMz.s from 1999-2007 at the Tacoma Monitoring Site

100 80**M~** 60 

### "' 0 

### £ 40 IL

100 80**.,~** 60 

### "' 0 

## -:r 40 IL 0 10 Tacoma Summer (April - Septemberj1999-2007

20 30 " R2

## = 0.43 40 robust regression 2.44x+0 .26 ordinary LS 1.9x+6.4 50 60 70 Tacoma Winter (October-Marchj1999-2007

R2 

## = 0.84



### Figure 4.2.6: Estimated PM10 to Measured PMto for the years 1999-2007



### ., 

# .. Oi 

## ., 

# e 0 100 90 80 70 60 50 

# f 40 30 20 Tacoma Estimated PM 10

• ordinary LS 0.68x+6 .5

-- robust regression 0.997x+0 .01

PM 10 measured 

### 36 

## .....

# ···· .. ........

## ···



# .....

# ···

90 100

### PM1o 

### Violation Unlikely EPA analysis- this demonstration shows that the more stringent 35 11g/m 3 24-hour PM 2 .5 standard would be violated well before a possible exceedance of the 24-hour PM 10 standard of 1501lg/m 3 in these three maintenance areas . Compliance with the 2006 24-hour PM 2 .5 standard of 35 11g/m 3 will help assure continued compliance with the 1987 PM 1o standard . PSCAA ran collocated FRM/ FEM PM 10 and FRM/FEM PM 2 .5 monitors from 1999 through 2007. Using the relationships described in the model development section above , we can estimate the measured PM 2 .5 concentrations that would suggest an exceedance of the 24-hour PM 10 standard of 1501lg/m 3 in the summer and winter seasons . PM 2 .5 concentrations that would be required to exceed the 24-hour PM 10 standard are summarized in Table 4.2. 1. 

### Table 4.2.1 PMz.s 

### concentrations correspondingto a PMto 

### concentration of 150**~gjm 3**  Summer PMz.s Max Summer Winter PMz.s Max Winter Concentration (1J.g/m 3 ) PMz.s (1J.g/m 3)* Concentration (1J.g/m 3 ) PMz.s (1J.g/m 3 ) since 2008 since 2008 Kent 75 

### 71 * 122 33 Seattle 79 28 113 34 Tacoma 62 35 114 53 *Maximum value was observed on July 41h, 2009 . The second highes t value at Kent from 2008-2012 is 281lg/m 3 The maximum summer and winter PM 2 .5 concentrations observed at each of the monitoring sites from 2008-2012 are listed in Table 4.4 . 1 . Using the relationship between PM 10 and PM 2 .5, 24-hour PM 2 .5 levels would have to exceed , at a minimum , 62 11g/m 3, in summer or at least 113 11g/m 3 in the winter to exceed the PM 10 standard at any of the three maintenance area monitoring sites. Because of the form of the PM 10 standard, the PM 2 .5 level would have to be exceeded more than once a year, over a three year average , to violate the PM 10 standard. For example the 711lg/m 3, recorded at Kent on July 4, 2009 , corresponds to a PM 10 concentration of 142 11g/m 3

. While 142 11g/m 3 is near the NAAQS of 150 11g/m 3, it is not an exceedance . However, the PM 2 .5 concentration of 7lllg/m 3 is well above the NAAQS of 35 11g/m3

. This demonstrates that PM 2 .5 is the controlling standard . The maximum observed PM 2 .s concentrations in table 4.4 . 1 demonstrate that an exceedance of the PM 10 NAAQS is highly unlikely.



### 37

## 4.3. Current PMto 

## and PMz.s 

## Data Availability EPA analysis- this approach is similar to the recently approved Thurston County action . Data and summary results are readily available to the public on the website links below, and are submitted to the EPA annually in accordance with the limited maintenance plan option memo . PM 10 concentrations calculated from the PM 10 model described above are available from PSCAA and can be provided to EPA and the public on request. Both the 3-year and 5-year design values will be included in Ecology's annual monitoring network report to EPA, this report is available to the public at https://fortress.wa.gov/ecy/publications/UIPages/Home.aspx The PM 2.5 monitored concentrations used to calculate the PM 10 concentrations are available from the PSCAA website, www.pscleanair.org.

38

## 5. Emission Inventory EPA analysis- due to the steadily declining PM 10 

### levels and emission sources, this emissions inventory is generally straightforward and noncontroversial. In order to address any potential questions or issues related to locomotive transport of coal, PSCAA worked closely with Robert Kotchenruther to include estimated fugitive dust emissions for the locomotive sector along with the more traditional diesel emission impacts reported as part of the National Emissions Inventory. Total locomotive emissions represent a small proportion of the overall PM 10 

### inventory (Kent= 6%, Seattle= 5%, and Tacoma = 2%) and are unlikely to interfere with continued maintenance given the current low levels of PM 10 

### monitored in the area . As shown by the maintenance area maps, all three monitors are located close to major rail lines. Therefore, continued monitoring of attainment and qualification under the limited maintenance plan option will be easy to verify over time . For more information on development of the inventory and the inventory preparation plan developed with the EPA and Ecology, please see Appendices C and D of the PSCAA submission.

This section presents the emissions inventory for this second 10-year maintenance plan and briefly describes its development. The LMP Guidance requires the maintenance plan include an attainment inventory-that is, an inventory with emission levels consistent with attainment ofthe PM 10 

### standard. EPA develops a triennial national emission inventory based on EPA and state inputs. EPA issued the Air Emissions Reporting Rule (AERR) to clarify state reporting requirements. EPA and Ecology agreed on developing the attainment inventory from available triennial inventory information and annual reported industrial emissions . Appendix C provides details on the emission inventory development. 

### Emission years and categories EPA approved the Inventory Preparation Plan (IPP) prepared by Ecology that proposed use of readily available information . This plan is provided as Appendix D. Emission estimates in this maintenance plan inventory are from Ecology's draft 2011 triennial emissions inventor/ (2011 El} and the annual 2011 industrial emissions reported to PSCAA and Ecology. The original seven significant emission categories are reorganized in seven new categories in this attainment inventory as listed in Table 5.1. County values from the seven most significant categories have been temporally and spatially allocated to their respective maintenance areas . These seven emissions categories were chosen based on a review of the emission sources in the original maintenance plan.

7 Draft Excerpts of the Washington State Base Year 2011 County Inventories, Wash i ngton State Department of Ecology Air Quality Program , Sally Otterso n, 2013. 39

### Table 5.1: Emission Categories used in this LMP 1994 Emissions Categories 2011 Emission Categories Gasoline Exhaust On-road Mobile Diesel Exhaust Port and Marine, On-road Mobile Ships Port and Marine Locomotives Locomotives (including fugitive dust) Wood Burning Residential Wood Combustion Road Dust Paved Road Dust, Unpaved Road Dust Allowable Industrial Industrial 

### Emission inventory geography The emission inventory is an estimate of the total PMlO tons boundaries shown in the Figure 

### 2.1, Figure 

### 2.2, and Figure 2.3.

40

### Significant source categories The most significant sources of PM 10 

### listed in the original maintenance plan for the Seattle and Tacoma Maintenance Areas was industrial emissions. For the Kent Maintenance Area, the major source of emission was from Residential Wood Combustion, and to a lesser extent diesel and gas vehicle exhaust. Fugitive dust emissions from coal trains were estimated and are included in the total locomotive emissions, see Appendix C. 

### Other sources are deemed insignificant, including outdoor burning, construction dust, aircraft emissions, wildfires, cigarette smoke, commercial charbroiling , and secondary particulate matter. Outdoor burning is prohibited in the three maintenance areas, so emissions would be minimal. Neither Ecology nor PSCAA have local information on emissions for construction dust, cigarette smoke, or commercial charbroiling, but is assumed to be minimal in these areas. Smoke from wildfires in Puget Sound is rare and was considered negligible . Some of these values are included in the 2011 NEI, however the emission estimates have large uncertainties because the data was collected nationally and was not developed specifically for local areas, or for sub-county regions like the Seattle, Tacoma, and Kent Maintenance Areas.

41

### Maintenance Plan Inventory Emissions for these seven emission categories are shown in Table 5.2 below. Washington State' s 2011 El is the most recent, complete, readily available emission inventory for King and Pierce County. 

### Table 5.2: Seattle, Tacoma, and Kent Maintenance Area Annual and Winter Day PM1o Emissions Seattle Duwamish Tacoma Tideflats Kent <II 

### > > IJ n:J n:J 

# ... ...**~** "C Ill :::J n:J 

# ... ... <II 0 <II 

# ... > <II 

# ... > <II 

# ... > ·;: II) 

### > > n:J 

### ..... > n:J 

### ..... > n:J 0**~** 

### t ........**~** c:: ........**~** c:: 

### ........**~** tl.O Ill 

# ... '§: Ill 

# ... '§: Ill 

# ... <II 0 0 c:: <II c:: <II c:: <II 

### ..... ..... c. 0 

### ..... ........ 0 

### ..... ........ 0 

### ..... n:J c:: <II 

### ..... c:: Ill 

### ..... c:: Ill 

### ..... c:: u <II 

### a:: '§: c:: 

### '§: c:: 

### '§: c:: > n:J 0 n:J 0 n:J 0 c:: c:: :::J ........ 

### ..... :::J ........ 

### ..... :::J 

### ........ 

# - 0 

### ·u; c:: Ill c:: Ill c:: Ill c:: 

### ·u; c:: n:J c:: n:J c:: •!!! 0 Ill c:: 0 

### ..... c:: 0 

### ..... c:: 0 <( 0 <( 0 <( 

### E 

### ·u; 

# ·e 1- 

### ..... 1- 

### ..... 1- w Ill 

# - - ·e w 0 0 w 

# '* '* On-road Mobi le 2011 El 2011 1 00 .8 0.29 12% 59 .9 0 . 17 11% 2 1.7 0.06 Port and Marine 2011 El 2011 122 .2 0 .33 14% 77 .0 0 .21 14% 0 .0 0 .00 Locomotives (including fugitive 2011 El 2011 43 .5 0. 12 5% 13 .4 0 .04 2% 13.8 0 .04 dust) Resident ial Wood 2011 El 2011 Combustion 17.0 0.13 5% 6.6 0 .05 3% 34 .8 0 .26 Paved Road Dust 2011 El 2011 190. 1 0.53 22% 104.6 0 .29 19% 40 .9 0. 11 Unpaved Road Dust 2011 El 2011 133 .6 0.65 27% 23.3 0 . 11 7% 28.7 0.14 Industrial PSCAA, Ecology 2011 127.3 0.35 15% 243 .4 0 .67 43% 0.5 0.00 Total -- 2011 734.5 2.40 

## -- 140. 528.2 1.53 

## -- 0.61 4

42 

### > n:J**~** 

# ... <II 

### ..... c:: 

### '§:

........ Ill c:: 0



### ..... 

# - n:J 

### ..... 0



### ..... 

# - 0 

# '* 10% 0% 6%

42% 18% 23% 0%



## --

## 6. Control Measures EPA analysis- the suite of control measures that brought the three areas into attainment continue to remain in place in accordance with the limited maintenance plan option memo. Additionally, due to efforts to address the more stringent PM 2.5 standard, many of these control measures have strengthened over time, such as the residential wood combustion regulations and diesel programs . PSCAA and Ecology relied upon Reasonably Available Control Measures (RACM) for residential wood combustion and fugitive dust to return the three maintenance areas to compliance with the 1987 PM 10 standard. In addition to the RACM for wood smoke and fugitive dust, PSCAA and Ecology have enforceable and permanent control measures for industrial sources and outdoor burning . Improved federal standards for diesel emissions have also helped to control emissions. PSCAA and Ecology continue to implement the control measures included in the attainment plan and the first maintenance plan. Federal, PSCAA, and Ecology rules provide the legal authority to implement, maintain, and enforce the control measures in this plan . Control measures are listed below, with further explanation and references following:



### Wood Smoke Curtailment

• Mandatory curtailment and enforcement program during impaired air quality (PSCAA Regulation 1, Article 13.05) • Opacity limits (PSCAA Regulation 1, Article 13.03) • Fuel restrictions (PSCAA Regulation 1, Article 13.04) • Prohibition and sale of uncertified wood stoves (PSCAA Regulation 1, Article 13 .07) • Allow woodstoves to be prohibited entirely as a SIP contingency measure (PSCAA Regulation 1, Article 13.07 (b)) • Certification of new woodstoves (PSCAA Regulation 1, Article 13 .02) • Rules that govern the sale and transfer of uncertified stoves (PSCAA Regulation 1, Article 13.06) 

### Fugitive Dust Control Measures

• Prevent spillage and track out of dirt and mud on to public roadways (PSCAA Regulation 1, Article 9.15(a)(4)) • Improved industrial hygiene (PSCAA Regulation 1, Article 9.1S(a)) 

### Industrial Source Program

• Modifications of existing major sources • Boiler replacement • Facility Shutdown • Monitoring opacity of emissions (PSCAA Regulation 1, Article 9.04) • Emissions standards in PSCAA Regulation I- Article 9 and Chapter 173-400 WAC 43• PSCAA Orders of Approval and Ecology Regulatory Orders for Simpson Tacoma Kraft 

### Diesel Programs

• Emissions have been reduced as a result of federal regulations on the sulfur content of diesel fuel and the particulate emissions of new vehicles . • Chapter 173-422A WAC requires heavy duty vehicles registered in Kent, Seattle, and Tacoma to pass a vehicle inspection and pass specific emissions standards . 

### Outdoor Burning Restrictions

• Land clearing is prohibited in King and Pierce Counties (PSCAA Regulation 1, Article 8.13) • Residential yard waste burning is prohibited in urban growth areas in King and Pierce Counties (PSCAA Regulation 1, Article 8.9 and 8.10) 

### Emission Reduction Program. s The following programs are believed to be responsible for the region maintaining compliance with the ambient air quality standard . Where applicable, we have also included voluntary measures that reduce emissions under the appropriate category (explicitly noted voluntary) . Unless noted voluntary, the emission reductions listed below are considered permanent and enforceable . 

### Wood Smoke Curtailment PSCAA successfully implements the curtailment program in the Kent, Seattle, and Tacoma PM 10 maintenance areas . Mandatory curtailment and enforcement of solid fuel burning devices is outlined in PSCAA Regulation I, Article 13 .05 . When wood smoke pollution is forecasted to impair air quality, PSCAA restricts wood burning . When PSCAA calls burn bans for the area, woodstove use and outdoor burning are restricted or prohibited. Burn bans do not apply to homes without another source of adequate heat. PSCAA calls burn bans in two stages . A Stage 1 ban prohibits all uncertified wood heating devices when pollution approaches unhealthful levels. A Stage 2 ban prohibits all wood heating when pollution reaches a specified higher level. Unhealthful levels are defined as follows: a Stage 1 burn ban (First Stage of Impaired Air Quality) is declared when meteorological conditions are forecast to cause fine particulate levels to exceed 35 11g/m 3 within 48 hours, when measured on a 24 hour average basis (or 30ug/m 3 within 72 hours in counties with a PM2.5 nonattainment area- this includes Pierce County). A Stage 2 burn ban (Second Stage of Impaired Air Quality) is declared when a first stage of impaired air quality has been in force and has not been sufficient to reduce the increasing fine particulate pollution trend. Under certain circumstances a Stage 2 ban may be declared without calling a Stage 1 ban first. Since Stage 1 and Stage 2 burn bans are designed to maintain the more stringent 2006 PM 2.5 standard, PSCAA's burn ban rules are more protective ofthe PM 10 standard than the state burn ban rules

44supporting the attainment and first 10-year maintenance plan for Kent, Seattle, and Tacoma PM 10 maintenance areas. 

### Fugitive Dust Spillage and track out of dirt and mud onto public roadways is regulated in section 9. 15(a) of Regulat ion I in the PSCAA rules. The PSCAA fugitive dust program has been determined by EPA to meet the RACM requirements in CAA Section 189(a)(1)(C) . The emission reductions from this program are considered both permanent and enforceable . 

### Industrial Sources Reductions in actual and allowable emissions from industrial sources have occurred as a result of facilities permanently shutting down as well as new federal regulations for specific stationary sources. The National Emission Standards for Hazardous Air Pollutants (NESHAPS) are stationary sou rce standards for hazardous air pollutants (40 CFR Part 61 and 40 CFR Part 63) . Particulate matter is regulated in NESHAPs found in 40 CFR Part 63 . Section 111 of the Clean Air Act authorized the EPA to develop technology based standards which apply to specific categories of stationary sources. These standards are referred to as New Source Performance Standards (NSPS) and are found in 40 CFR Part 60. The NSPS apply to new, modified and reconstructed affected facilities in specific source categories such as manufacturers of glass, cement, rubber tires and wool fiberglass .8 The NSPS apply to industrial sources in the Tacoma and Seattle PM 10 maintenance areas . Emission standards contained in Article 9 of PSCAA Regulation I and Chapter 173-400 WAC as well as PSCAA Orders of Approval and the Ecology Regulatory Orders for Simpson Tacoma Kraft have been determined by EPA to be permanent and enforceable . 

### Diesel Emissions National diesel fuel standards have significantly reduced sulfur content in diesel fuel since 1997 . The diesel program regulations are located in 40 CFR Part 80 subpart I. A 15 parts per mill ion (ppm) sulfur specification, known as Ultra Low Sulf ur Diesel (ULSD) , was phased in fo r highway diesel fuel from 2006- 2010 . Diesel engines equipped with advanced emission control devices (general ly, 2007 and later model year engines and vehicles) must use highway ULSD fuel. Exhaust emiss ions fro m t hese engines w ill decrease by more than 90%.9 Low sulfur (500 ppm) and Ultra Low Su lfur Diesel (ULSD) fuel wil l be phased in for non-road, locomotive, and marine (NRLM) engines from 2007-2014. These fuel requirements, coupled with advanced em ission control techno logies, will decrease emissions from these engines by more than 90%.9 EPA adopted changes to the diese l fuel program to allow for t he production and sale of diese l fue l with up to 1 ,000 ppm sulfur for use in Category 3 marine vessels. The regul ations generally forb id production and sale of fuels with more than 1,000 ppm sulfur for use in most U.S. waters, unless operators ach ieve equ ivalent em ission reductions in other ways9.

8 New Source Performance Standa rds and State impl ementation Pla ns http ://www.epa .gov/compliance/moni.toring/programs/caa/newsource.html 9 EPA Diesel Fuel Page http ://epa.gov/otaq/fuels/dieselfuels/index.htm 

### 45In 2010, the International Maritime Organization designated specific portions of U.S. waters as an Emission Control Area (ECA). In our region, the ECA extends out to approximately 200 nautical miles west of the West Coast. The ECA became enforceable in August 2012, but the most stringent fuel sulfur reductions will come into effect in January 2015. The ECA will reduce the sulfur content in fuels from an average of about 2.7% sulfur to 0.1% sulfur by January 2015. This cleaner fuel will result in decreases in both sulfur oxides and PM 10 pollution in the Tacoma and Seattle Maintenance Areas. It should reduce emissions from ocean-going ships of sulfur oxides by approximately 95% and PM 10 pollution by approximately 60 to 80%. 

## Voluntary diesel emissions reductions: Strategies for reducing diesel emissions in the Kent, Seattle, and Tacoma PM 10 maintenance areas have been achieved through the PSCAA Diesel Solutions Program as well as the Northwest Ports Clean Air Strategy. These programs target emissions in four transportation sectors: off-road equipment, on-road vehicles, maritime vessels and equipment, and rail. Off-road: Off-road diesel emissions include construction equipment, aircraft-support equipment, and cargo handling equipment used at seaports and rail yards . Voluntary strategies to reduce diesel emissions in the off-road sector include cleaner fuels, retrofit technologies and vehicle replacement. Through the voluntary programs, cargo handling equipment has been retrofitted and replaced in the Seattle and the Tacoma PM 10 maintenance areas. On-road and School Buses: Voluntary strategies to reduce diesel emissions from the on-road sector include cleaner fuels, retrofit technologies and vehicle replacements . Between 2003 and 2008 PSCAA retrofitted school busses through the Puget Sound region with diesel oxidation catalysts and crankcase filters. As part of the Puget Sound Clean Cities Petroleum Reduction Project, waste hauling fleets are reimbursed for the cost difference between a conventional diesel truck and a natural gas or hydraulic-hybrid natural gas truc_k Ports: Since both The Port of Tacoma and The Port of Seattle fall within two of the maintenance areas, diesel reduction projects at the ports have contributed to reducing emissions. Public and private fleets in The Port of Seattle were replaced with new trucks and diesel oxidation catalysts as part of the Diesel Solutions Program between November 2009 and January 2011. Through the voluntary programs, cargo handling equipment has been retrofitted and replaced in both the Seattle and the Tacoma PM 10 maintenance areas . As part of the Puget Sound Clean Cities Petroleum Reduction Project, waste hauling fleets are reimbursed for the cost difference between a conventional diesel truck and a natural gas or hydraulic-hybrid natural gas truck.

46

### Outdoor burning . While not considered a significant contributor to high PM 10 concentrations on stagnant winter days, outdoor burning of land clearing debris and yard waste has potential for caus ing violat ions of the PM 10 standard . In 2000 and 2008 Article 8 of Regulation I was amended to prohibit residential yard burning in the King and Pierce Co unty urban growth areas as well as the former ca rbon monoxi de non-atta inment area (Seattle/Tacoma/Everett urban areas, as defined by the Washington State Department of Transportation , 1983 vers ion , urban area maps). Article 13 of Regulation 1 prohib its land clearing burning completely in King and Pierce counties . PSCAA continues to encourage development of alternatives to outdoor burn ing such as chipping , composting and yard waste collection programs . 

### Control Measures in PSCAA Rules Washington State' s Clean Air Act grants the authority fo r and outlines the conditions under wh ich PSCAA may adopt its own rules . PSCAA has jurisdiction over the Kent, Seattle, and Tacoma PM 10 maintenance areas and relies upon its rules to maintain and enforce the PM 10 standard. The PSCAA ru les as listed in Table 6. 1 , Table 6.2, and Table 6.3 are incl uded in the federally approved SIP . 

### Table 6.1: PSCAA Regulation I -Article 8: Outdoor Burning Regulation I -Article 8: Outdoor Burning State Adoption EPA Effective Date 8.04 General Cond itions for Outdoor Burn ing 11/9/2000 9/30/2004 8.05 Ag ricu ltural Burn ing Permits 11/9/2000 9/30/2004 8.06 Outdoor Burning Ozone Contingency Measure 12/19/2002 9/7/2004 8.09 Description of the King County No-Burn Area 11/9/2000 9/30/2004 8. 10 Description of the Pierce County No- Burn Area 11/9/2000 9/30/2004 8.11 Description of the Snohom ish County No-Burn Area 11/9/2000 9/30/2004 8. 12 Description of the Kitsap County No-Burn Area 1 0/24/2002 9/30/2004 

### Table 6.2: 

### PSCAA Regulation I- Article 9: Emission Standards Regulation I -Article 9: Emission Standards State Adoption EPA Effective Date 9.03 Emission of Air Contaminant: Visual Standard 3/11/1999 9/30/2004 9.04 Opacity Standard for Equipment with Continuous Opacity 4/9/1998 9/30/2004 Monitoring Systems 9.05 Refuse Burning 12/9/1993 6/29/1995 9.08 Fuel Oil Standards 4/14/1994 6/29/1995 9.09 Particulate Matter Emission Standards · 4/9/1998 9/30/2004 9.15 Fugitive Dust Control Measures 3/11/1999 9/30/2004 9.16 Spray-Coating Operations 7/12/200 1 9/30/2004 9.20 Maintenance of Equipment 6/9/1988 10/28/1994 

### 47

### Table 6.3: PSCAA Regulation I- Article 13: Solid Fuel Burning Device Standards Regulation I -Article 13: Solid Fuel Burning Device Standards State Adoption EPA Effective Date 13 .03 Opacity Standards 10/25/2012 6/28/2013 13 .04 Allowed and Prohibited Fuel Types 10 / 25/2012 6 / 28/2013 13 .05 Restrictions on Operation of So li d Fuel Burn ing Devices 10/25/2012 6/28/2013 13 .06 Emission Performance S t andards 10/25/2012 6/28/2013 13 .07 Prohibitions on Wood Stoves that are not Certified 10/25/2012 6/28/2013 Wood Stoves

48

## 7. Contingency Measures EPA analysis-- PSCAA's Regulation 1-Article 13.07 (b) remains in place and is part of the approved, federally enforceable SIP codified in 40 CFR 52 , Subpart WW . CAA Section 175(A) requires a maintenance plan include contingency measures necessary to ensure prompt correction of any violation of the standard that may occur after redesignation. PSCAA's Regulation 1- Article 13.07 (b) provides for prohibition of the use of uncertified woodstoves for the sole purpose of meeting CAA requirements for contingency measures. To implement this provision, the rule requires that the EPA, in consultation with Ecology and PSCAA, must make written findings that: (1) The area has failed to maintain a national ambient air quality standard (2) Emissions from solid fuel burning devices from a particular geographic area are a contributing factor to such failure to make reasonable further progress or attain or maintain a national ambient air quality standard 

### Contingency Measure Trigger The contingency measure will be triggered if a violation of the PM 10 standard occurs at the maintenance area monitor based on nephelometer and/or FRM monitoring . A violation of the PM 10 standard will be determined by the procedures outlined in 40 CFR Part 50.



### 49

## 8. Commitment to Continued Monitoring and Verification ofContinued Attainment EPA analysis- this section is consistent with the previously approved Thurston County PM 10 plan.

Emissions in the Kent, Seattle, and Tacoma PM 10 maintenance areas are not expected to grow to threaten compliance with the standard as discussed in Section 3 ofthis plan . PSCAA makes a commitment to continue operation of PM 2.5 monitors in the Kent, Seattle, and Tacoma PM 10 maintenance areas through 2020, the end of the maintenance period . The PM 2.5 measurements will be used to calculate PM 10 levels in the maintenance areas. In the unlikely event that after exceptional events are taken into account (using EPA guidance), the calculated design value for PM 10 exceeds the LMP threshold of 98!1g/m 3, PSCAA will reestablish PM 10 monitoring as part of the annual network monitoring report process. PM 10 concentrations calculated from the PM 10 model described in section 4.3 are available from PSCAA and can be provided to EPA and the public on request. The PM 2.5 monitored concentrations used to calculate the PM 10 concentrations are available from the PSCAA website, www.pscleanair.org. Both 3-year and 5-year design values will be provided annually to Ecology for the annual monitoring network report. The network review is available at https://fortress.wa .gov

### Iecy/publ ications/U IPages/Home .aspx PSCAA will calculate 3-year and 5-year PM 10 design value estimates annually for the Kent, Seattle, and Tacoma maintenance areas through 2020 to confirm the areas continue to meet the PM 10 NAAQS. A 3- year PM 10 design value estimate of or below 150 11g/m 3 demonstrates continued compliance with the PM 10 NAAQS . Ecology will include a statement in the annual network report to inform EPA of continued attainment for the Kent, Seattle, and Tacoma PM 10 maintenance areas based on calculated PM 10 values.

50

## 9. Summary ofMaintenance Plan Commitments EPA analysis- this section details work sharing between Ecology and PSCAA. In the unlikely event PSCAA cannot fulfill the obligations below, Ecology as the Governor's designee will be responsible for fulfilling these commitments . Commitments made in this maintenance plan are summarized in Table 9. 1 . 

### Table 9.1: Second 10-Year LMP Commitments Section Commitment Responsible Agency 

### 3 Annual calculation ofthe Kent, Seattle, and Tacoma PM 10 

### 5-year PSCAA design values through 2020 to show continued qualification for the LMP option . 

### 3 Reporting to EPA on continued qualification for the LMP option in Ecology the annual monitoring network report 

### 7 Implementation ofthe contingency measure if the Kent, Seattle, PSCAA or Tacoma maintenance area violates the PM 10 

### standard based on PM 2.s monitoring 

### 8 Continued monitoring of PM 2 .5 

### in the Kent, Seattle, and Tacoma PSCAA maintenance areas through 2020 

### 9 Annual calculation of the 3-year PM 10 

### design values for the Kent, PSCAA Seattle, and Tacoma maintenance areas through 2020 to assess compliance with the PM 10 

### standard 

### 9 Reporting to EPA on continued PM 10 

### attainment in the annual Ecology monitoring network report The PM 10 

### attainment plan for Kent was fully approved by EPA on July 27, 1993 {58 FR 40059) and the plans for Tacoma and Seattle were fully approved by EPA on October 25, 1995 and October 26, 1995, respectively {60 FR 54599 and 60 FR 54812) . EPA approved the first 10-year maintenance plan on March 13, 2001 {66 FR 14492) . This plan ensures compliance through 2020 and fulfills the final requirement for maintenance plans specified by the CAA.

51

### AttachmentB -- 

### thefollowing sampleproposed Federal Register notice is intended to identify key issues in review of PSCAA IEcology's draft. Upon receipt of a

final SIP revision, the EPA will review any changes to the SIP submittal as a result of local and statepublic comment processes or any relevant EPA polic y changes to adapt this sampleproposedFederal Register notice as appropriate.

6560-50-P ENVIRONMENTAL PROTECTION AGENCY 40 CFR Part 52 [Docket#: EPA-R10-0AR-2013-0713; FRLApproval and Promulgation ofImplementation Plans; \Vashington: Kent, Seattle, and Tacoma Second 10-Year PM 10 

### Limited Maintenance Plan AGENCY: Environmental Protection Agency (EPA). ACTION: Proposed rule. SUMMARY: The EPA is proposing to approve a limited maintenance plan submitted by the State ofWashington on XXXX, 2013, for the Kent, Seattle, and Tacoma maintenance areas for particulate matter with an aerodynamic diameter less than or equal to a nominal 10 micrometers (PM 10). 

### A limited maintenance plan is used to meet Clean Air Act requirements for formerly designated nonattainrnent areas with little risk ofviolating the PM 10 

### National Ambient Air Quality Standard (PM 10 

### NAAQS) again. All three areas currently have monitored PM 10 

### levels that are roughly one-third ofthe PM 10 

### NAAQS , with steady declines in PM 10 

### levels since the areas were first identified as potentially violating the PM 10

### NAAQS in 1987. DATES: Comments must be received on or before [INSERT DATE 30 DAYS FROM THE DATE OF PUBLICATION IN THE FEDERAL REGISTER].

### ADDRESSES: Submit your comments, identified by Docket ID No. EPA-RlO-OAR-2013-0713, by any ofthe following methods: A. www.regulations.gov: Follow the on-line instructions for submitting comments. B. Mail: JeffHunt, EPA Region 10, Office ofAir, Waste and Toxics (AWT-107), 1200 Sixth Avenue, Suite 900, Seattle WA, 98101 C. E-mail: RIO-Public Comments@. epa.gov D. Hand Delivery: EPA Region 10 Mailroom, 9th Floor, 1200 Sixth Avenue, Suite 900, Seattle WA, 98101. Attention: JeffHunt, Office ofAir, Waste and Toxics, AWT1

07. Such deliveries are only accepted during normal hours ofoperation, and special arrangements should be made for deliveries ofboxed information Instructions: Direct your comments to Docket ID No. EPA-RlO-OAR-2013-0713. The EPA's policy is that all comments received will be included in the public docket without change and may be made available online at www.regulations.gov, including any personal information provided, unless the comment includes information claimed to be Confidential Business Information (CBI) or other information the disclosure ofwhich is restricted by statute. Do not submit information that you consider to be CBI or otherwise protected through www.regulations.gov or e-mail. The www.regulations.gov website is an "anonymous access" system, which means the EPA will not know your identity or contact information unless you provide it in the body ofyour comment. Ifyou send an e-mail comment directly to the EPA without going through www.regulations.gov your e-mail address will be automatically captured and included as part ofthe comment that is placed in the public docket and made available on the Intemet. Ifyou submit an electronic comment, the EPA recommends that you include your 2

### name and other contact information in the body ofyour comment and with any disk or CD-ROM you submit. Ifthe EPA cannot read your comment due to technical difficulties and cmmot contact you for clarification, the EPA may not be able to consider your comment. Electronic files should avoid the use ofspecial characters, any fonn ofencryption, and be free ofany defects or viruses. Dock et: 

### All documents in the electronic docket are listed in the www.regulations.gov index. Although listed in the index, some information is not publicly available, i.e., CBI or other infonnation the disclosure ofwhich is restricted by statute. Certain other material, such as copyrighted material, is not placed on the Internet and will be publicly available only in hard copy form. Publicly available docket materials are available either electronically in www.re2:ulations.gov or in hard copy during normal business hours at the Office ofAir, Waste and Toxics, EPA Region 10, 1200 Sixth Avenue, Seattle WA, 98101. 

### FOR FURTHER INFORMATION CONTACT : Jeff Hunt at (206) 553-0256, hunt.jeft@epa.gov, or by using the above EPA, Region 10 address. 

### SUPPLEMENTARY INFORMATION: Throughout this document wherever "we", ''us" or "our" are used, it is intended to refer to the EPA. 

### Table of Contents I. 

### This Action II. Background III. Public and Stakeholder Involvement in Rulemaking Process IV. The Limited Maintenance Plan Option for PM 10 

### Areas A. Requirements for the Limited Maintenance Plan Option B. Conformity under the Limited Maintenance Plan Option V. Review ofthe State' s Submittal A. 

### Has the State Demonstrated that the Maintenance Areas Qualif y for the Limited Maintenance Plan Option? B. Does the State Have an Approved Attaimnent Emissions Inventory? C. Does the Limited Maintenance Plan Include an Assurance ofContinued Operation of 3

### an Appropriate EPA-Approved Air Quality Monitoring Network, in Accordance with 40 CFR Part 58? D. Does the Plan Meet the Clean Air Act Requirements for Contingency Provisions? E. Has the State Met Conformity Requirements? VI. Proposed Action VII. Statutory and Executive Order Reviews I. 

### This Action The EPA is proposing to approve the limited maintenance plan submitted by the State of Washington (Washington or the State) on XXXX, 2013, for the Kent, Seattle, and Tacoma PM 10 maintenance areas, including approval ofa monitoring system modification for the area. If finalized, the EPA's approval ofthis limited maintenance plan will satisfy the section 175A Clean Air Act requirements for all three areas, including the portion ofthe Puyallup Indian Reservation that falls within the Tacoma PM 10 maintenance area. 

### II. Background On August 7, 1987, the EPA identified portions ofKent, Seattle, and Tacoma as "Group I" areas ofconcern for having a greater than 95% probability ofviolating the 24-hour PM 10 

### NAAQS (52 FR 29383). On November 15 , 1990, the Group I areas ofKent, Seattle, and Tacoma were designated as nonattainment for PM10 by operation oflaw upon enactment ofthe Clean Air Act Amendments. The Washington Department ofEcology (Ecology) and the Puget Sound Clean Air Agency (PSCAA) worked with the communities to establish PM 10

### pollution control strategies. Primary control strategies for the three areas included a residential wood

· smoke control program, a fugitive dust program, a prohibition on open burning, and industrial emission controls. These control measures were highly successful with monitoring data showing Kent, Seattle, and Tacoma meeting the PM10 NAAQS since 1987, 1990, and 1989, respectively, with continuing declines in PM 10 levels ever since. 4

### The EPA fully approved the PM 10 attainment plans for Kent, Seattle, and Tacoma on July 27, 1993, October 26, 1995 , and October 25 , 1995, respectively (58 FR 40059,60 FR 54812, and 60 FR 54599). The EPA then approved a 1 0-year maintenance plan redesignating all three areas from nonattainment to attainment, making them maintenance areas effective May 14, 2001 (66 FR 14492, published March 13 , 2001). The purpose ofthe current limited maintenance plan is to fulfill the second 10-year planning requirement, section 175A (b) 

### ofthe Clean Air Act, to ensure compliance through 2020 . 

### III. Public and Stakeholder Involvement in Rulemaking Process Section 110(a)(2) ofthe Clean Air Act requires that each State Implementation Plan (SIP) revision offer a reasonable opportunity for notice and public hearing. The State provided notice and an opportunity for public comment beginning September 27, 2013 , and ending November 4, 2013. Under the requirements of40 CFR 51.102(a), the State held a public hearing at 6:30pm on October 30, 2013 in the Mill Creek Room ofthe Kent Commons, 525 Fourth Avenue N, Kent, Washington. No comments were received. (confinn) This SIP revision was submitted by the Governor's designee and was received by the EPA on XXX .. '(, 2013. The EPA evaluated Ecology's submittal and detennined that the State met the requirements for reasonable notice and public hearing under section 11 0(a)(2). 

### IV. The Limited Maintenance Plan Option for PM 10 

### Areas A. Requirements for the Limited Maintenance Plan Option On August 9, 2001 , the EPA issued guidance on streamlined maintenance plan provisions for certain moderate PM 10 

### nonattainment areas. See memo from Lydia Wegman, Director, Air Quality Standards and Strategies Division, entitled "Limited Maintenance Plan Option for 5

### Moderate PM 10 

### Nonattainment Areas" (limited maintenance plan option memo). The limited maintenance plan option memo contains a statistical demonstration that areas meeting certain air quality criteria will, with a high degree ofprobability, maintain the standard ten years into the future. Thus, the EPA provided the maintenance demonstration for areas meeting the criteria outlined in the memo. It 

### follows that future year emission inventories for these areas, and some ofthe standard analyses to determine transportation conformity with the SIP, are no longer necessary. To qualify for the limited maintenance plan option the State must demonstrate the area meets the criteria described below. First, the area should have attained the PM 10 

### NAAQS. Second, the most recent five years ofair quality data at all monitors in 

## tpe area, called the 24- hour average design value, should be at or below 98 11g/m3

. 

### Third, the State should expect only limited growth in on-road motor vehicle PM 10 

### emissions (including fugitive dust) and should have passed a motor vehicle regional emissions analysis test. Lastly, the memo identifies core provisions that must be included in all limited maintenance plans. These provisions include an attainment year emissions inventory, assurance ofcontinued operation ofan EPA-approved air quality monitoring network, and contingency provisions. 

### B. Conformity under the Limited Maintenance Plan Option The transportation conformity rule and the general conformity rule (40 CFR parts 51 and 93) apply to nonattainment areas and maintenance areas covered by an approved maintenance plan. Under either conformity rule, an acceptable method ofdemonstrating a Federal action confonns to the applicable SIP is to demonstrate that expected emissions from the planned action are consistent with the emissions budget for the area. 6

### While qualification for the limited maintenance plan option does not exempt an area from the need to affirm conformity, conformity may be demonstrated without submitting an emissions budget. Under the limited maintenance plan option, emissions budgets are treated as essentially not constraining for the length ofthe maintenance period because it is unreasonable to expect that the qualifying areas would experience so much growth in that period that a violation ofthe PM 1

### oNAAQS would result. For transportation conformity purposes, the EPA would conclude that emissions in these areas need not be capped for the maintenance period and therefore a regional emissions analysis would not be required. Similarly, Federal actions subject to the general conformity rule could be considered to satisfy the "budget test" specified in 40 CFR 93.158 (a)(S)(i)(A) for the same reasons that the budgets are essentially considered to be unlimited. 

### V. Review of the State's Submittal A. Has the State Demonstrated that the Maintenance Areas Qualify for the Limited Maintenance Plan Option? As discussed above, the limited maintenance plan option memo outlines the requirements for an area to qualify. First, the area should be attaining the PM 10 

### NAAQS. Monitoring data shows that all three areas attained the PM 1

### o AAQS by 1990, with declining levels ofPM, oever since. The EPA formally redesignated the areas from nonattaimnent to attaimnent, making them maintenance areas effective May 14, 2001 (66 FR 14492, published March 13, 2001) . Second, the average design value for the past five years ofmonitoring data must be at or below the critical design value of98**~L g/** **3** 

### for the 24-hour PM 1 0 

### NAAQS. The critical design value is a margin ofsafety in which an area has a one in ten probability ofexceeding the 7

### NAAQS. The design values for Kent, Seattle, and Tacoma based on 24-hour PM 10 monitoring data from 2003 through 2007 are 57±3 Jlglm3, 

### 68±4

### ~Lg**,** and 72±9

### ~tg**.** As discussed later in this proposal, in these three areas PM 10 

### levels can be estimated with a high degree ofaccuracy using fine particulate matter (PM2.5) 

### concentrations. In 2007 , the EPA approved the State's request to shift from PM 10 specific monitoring in Kent, Seattle, and Tacoma to rely on the more stringent and environmentally relevant PM2.5 

### NAAQS monitoring effort. PM 10 

### design values estimated using PM2

### .s concentration levels from 2008 to 2012 are 46±3 Jlglm3, 

### 50±5 Jlglm3, 

### and 58±8**~tg ,**  

### respectively. The EPA reviewed the data and methodology provided by the State and finds that all three areas meet the design value criteria of98 Jlg/ m3 

### outlined in the limited maintenance plan option memo. Third, the area must meet the motor vehicle regional emissions analysis test described in Attachment B ofthe limited maintenance plan option memo . The State submitted an analysis showing that growth in on-road mobile PM 10 emissions sources was minimal and would not threaten the assumption ofmaintenance that underlies the limited maintenance plan policy. Using the EPA's methodology, the State calculated total growth in on-road motor vehicle PM 10 emissions over the ten-year period for Kent, Seattle, and Tacoma of 1.5 Jlg/m3, 

### 2.7 Jlg/m3, 

### and 2.9 Jlg/m3, 

### respectively. This calculation is derived using Attachment B ofthe EPA' s limited maintenance plan memo, where the projected percentage increase in vehicle miles traveled over the next ten years (VMTpi) is multipled by the on-road mobile portion ofthe attainment year inventory (DYmv ), 

### including both primary and secondary PM 1 0 

### emissions andre-entrained road dust. The EPA reviewed the calculations in the State's limited maintenance plan submittal and concurs with the determination that all three areas meet the motor vehicle regional emissions 8

### analysis test. This test is met when (VMTpi 

### x 

### DYmv ) plus the design value for the most recent five years ofquality assured data is below the limited maintenance plan threshold of 98 11g/m3

. 

### The results for Kent, Seattle, and Tacoma were 61.5 11g/m3, 

### 74.7 11g/m3, 

### and 83.9 11g!m3, 

### respectively. Please see Appendix A ofthe State's submission for the full analysis. Lastly, the limited maintenance plan option memo requires all controls relied on to demonstrate attainment remain in place for the areas to qualify. The EPA confirmed that the underlying control measures for Kent, Seattle, and Tacoma remain in place, thus qualifying for the limited maintenance plan option. As described above, the Kent, Seattle, and Tacoma maintenance areas meet the qualification criteria set forth in the limited maintenance plan option memo. Under the limited maintenance plan option, the State will be expected to determine on an annual basis that the criteria are still being met. Ifthe State determines that the limited maintenance plan criteria are not being met, it should take action to reduce PM 10 

### concentrations enough to requalify. One possible approach the State could take is to implement contingency measures. Section V. I. 

### provides a description ofcontingency provisions submitted as part ofthe limited maintenance plan submittal. To ensure this requirement is met, the State commits to reporting to the EPA on continued qualification for the limited maintenance plan option in the annual monitoring network report. 

### B. Does the State Have an Approved Attainment Emissions Inventory? Pursuant to the limited maintenance plan option memo, the State's submission should include an emissions inventory which can be used to demonstrate attainment ofthe NAAQS. The inventory should represent emissions during the same five-year period associated with air 9

### quality data used to determine whether the area meets the applicability requirements ofthe limited maintenance plan option. The limited maintenance plan submittal includes an emissions inventory based on the State's draft 2011 Triermial Emissions Inventory. This inventory is prepared as part ofthe 2011 National Emissions Inventory under the EPA's Air Emissions Reporting Rule (73 FR 76539, December 17, 2008). The information was supplemented with annual 2011 industrial emissions reported to PSCAA and Ecology. The 2011 base years represent the most recent emissions inventory data available and is consistent with the data used to detennine applicability ofthe limited maintenance plan option (i.e., having no violations ofthe PM 10 NAAQS). The emissions inventory focused on seven significant source categories chosen based on a review ofthe original maintenance plan. The 2011 emission categories are shown along with source categories from the original maintenance plan in parentheses. These categories are: on-road mobile (gasoline exhaust); port and marine, on-road mobile (diesel exhaust); port and marine (ships); locomotives, including fugitive dust (locomotives); residential wood combustion (wood burning) ; paved road dust, unpaved road dust (road dust); and industrial (allowable industrial). Other source categories, including outdoor burning, construction dust, aircraft emissions, wild±ires, cigarette smoke, commercial charbroiling, and secondary particulate matter, are insignificant. The EPA reviewed and is proposing to approve the emissions inventory and methodology. The emissions inventory data supporis the State's conclusion that the existing control measures in place will continue to protect and maintain the PM 10

### NAAQS. C. 

### Does the Limited Maintenance Plan Include an Assurance of Continued Operation of an Appropriate EPA-Approved Air Quality Monitoring Network, in 10

### Accordance with 40 CFR Part 58? PM10 monitoring was established in the Kent, Seattle, and Tacoma areas between 1985 and 1987, with many changes to the monitoring technology and requirements since. Beginning in 1999, the State collocated PM2.5 

### monitors with the existing PM 10 Federal Equivalent Method (FEM) monitors to establish correlation data and confirm that PM 10 levels could be accurately predicted using PM: u concentrations for the areas. Due to the high level ofcorrelation between the PM2.5 

### and PM 1 0 

### monitors, the State requested discontinuing the PM 10 specific monitors as part ofthe 2007 ammal network monitoring report under 40 CFR part 58. The EPA approved this request in a letter dated November 16, 2007, included in the docket for this action. A full description ofthe correlation data and the estimation model is included in the limited maintenance plan·submittal. The EPA is proposing to approve this monitoring system modification, using PM2.5

### monitoring data to estimate PM 10 

### concentrations, under 40 CFR I 

### 58.14(c) for the second 1 0-year maintenance plan period. This estimation method is a reproducible approach to representing air quality in all three maintenance areas, and all three areas continue to meet the applicable Appendix D requirements evaluated as part ofthe annual network approval process. As detailed in the limited maintenance plan, the State will calculate the PM 1 0 

### design value estimate annually from PM2.5 

### monitoring data through 2020 to confirm the area continues to meet the PM 1 0 

### NAAQS. The State also makes a commitment to continue operation ofPM2.5 

### monitoring in the three maintenance areas through the 2020, the end ofthe maintenance period, to detennine PM 10 levels . In the unlikely event that after exceptional events are taken into account, the calculated design value for PM 10 exceeds the limited maintenance plan threshold of98 )..lg/m3 , 

### the State will re-establish PM 10 monitoring. 11

### D. Does the Plan Meet the Clean Air Act Requirements for Contingency Provisions? Clean Air Act section 175A states that a maintenance plan must include contingency provisions, as necessary, to ensure prompt correction ofany violation ofthe NAAQS which may occur after redesignation ofthe area to attaim11ent. Puget Sound Clean Air Agency's Regulation I- Article 13 .07 (b) provides for prohibition ofthe use ofuncertified woodstoves for the sole purpose ofmeeting Clean Air Act requirements for contingency measures. The EPA approved Article 13.07 (b) 

### as a contingency measure for all three areas on March 13 , 2001 (66 FR 14492). Regulation I- Article 13.07 (b) 

### remains in effect today and the entire Article 13 was re-approved by the EPA on May 29,2013 (78 FR 32131). 

### E. Has the State Met Conformity Requirements? (1) 

### Transportation Confonnity Under the limited maintenance plan option, emissions budgets are treated as essentially not constraining for the maintenance period because it is unreasonable to expect that qualifying areas would experience so much growth in that period that a NAAQS violation would result. While areas with maintenance plans approved under the limited maintenance plan option are not subject to the budget test, the areas remain subject to the other transportation confonnity requirements of40 CFR part 93, subpart A. 

### Thus, the metropolitan planning organization (MPO) in the area or the State must document and ensure that: (a) transportation plans and projects provide for timely implementation ofSIP transportation control measures (TCMs) in accordance with 40 CFR 93 . 113 ; (b) 

### transportation plans and projects comply with the fiscal constraint element as set forth in 40 12

### CFR 93.108; (c) the MPO's interagency consultation procedures meet the applicable requirements of40 CFR 93.105; (d) conformity oftransportation plans is determined no less frequently than every four years, and conformity ofplan amendments and transportation projects is demonstrated in accordance**wit~** 

### the timing requirements specified in 40 CFR 93.1 04; (e) the latest planning assumptions and emissions model are used as set forth in 40 CFR 93 . 110 and 40 CFR 93.111; (f) projects do not cause or contribute to any new localized carbon monoxide or particulate matter violations, in accordance with procedures specified in 40 CFR 93.123; and (g) project sponsors and/or operators provide written commitments as specified in 40 CFR 93.125.Upon approval ofthe limited maintenance plan for the Kent, Seattle, and Tacoma areas, the three PM 10 

### maintenance areas are exempt from perfonning a regional emissions analysis, but must meet project-level confonnity analyses as well as the transportation conformity criteria mentioned above. (2) General Confonnity For Federal actions required to address the specific requirements ofthe general confonnity rule, one set ofrequirements applies particularly to ensuring that emissions from the action will not cause or contribute to new violations ofthe NAAQS, exacerbate current violations, or delay timely attaimnent. One way that this requirement can be met is to demonstrate that "the total ofdirect and indirect emissions from the action (or portion thereof) is 13

### determined and documented by the state agency primarily responsible for the applicable SIP to result in a level ofemissions which, together with all other emissions in the nonattaimnent area, would not exceed the emissions budgets specified in the applicable SIP" (40 CFR 93.l58(a)(5)(i)(A)). The decision about whether to include specific allocations ofallowable emissions increases to sources is one made by the state air quality agencies . These emissions budgets are different than those used in transportation confonnity. Emissions budgets in transportation conformity are required to limit and restrain emissions. Emissions budgets in general conformity allow increases in emissions up to specified levels. The State has not chosen to include specific emissions allocations for Federal projects that would be subject to the provisions ofgeneral confonnity. 

### VI. Proposed Action The EPA is proposing to approve the limited maintenance plan submitted by the State of Washington on XXXX, 2013 , for the Kent, Seattle, and Tacoma PM 10 

### maintenance areas, including approval ofa monitoring system modification for the area. Iffinalized, the EPA ' s approval ofthis limited maintenance plan will satisfy the section 175A Clean Air Act requirements for all three areas, including the portion ofthe Puyallup Indian Reservation that falls within the Tacoma PM 10 

### maintenance area. 

### VII. Statutory and Executive Order Reviews Under the Clean Air Act, the Administrator is required to approve a SIP submission that complies with the provisions ofthe Act and applicable Federal regulations. 42 U.S.C . 741 O(k) ; 40 CFR 52.02(a). Thus, in reviewing SIP submissions, the EPA's role is to approve state 14

### choices, provided that they meet the criteria ofthe Clean Air Act. Accordingly, this action merely approves state law as meeting Federal requirements and does not impose additional requirements beyond those imposed by state law. For that reason, this action: • is not a "significant regulatory action" subject to review by the Office ofManagement and Budget under Executive Order 12866 (58 FR 51735, October 4, 1993); • does not impose an infonnation collection burden under the provisions ofthe Paperwork Reduction Act (44 U.S.C. 3501 et seq.); 

### • is certified as not having a significant economic impact on a substantial number ofsmall entities under the Regulatory Flexibility Act (5 U.S.C. 601 et seq.); 

### • does not contain any unfunded mandate or significantly or uniquely affect small governments, as described in the Unfunded Mandates Reform Act of 1995 (Public Law 104-4); • does not have Federalism implications as specified in Executive Order 13132 (64 FR 43255, August 10, 1999); • is not an economically significant regulatory action based on health or safety risks subject to Executive Order 13045 (62 FR 19885, April23 , 1997); • is not a significant regulatory action subject to Executive Order 13211 (66 FR 28355 , May 22, 2001); • is not subject to the requirements of Section 12(d) ofthe National Technology Transfer and Advancement Act of 1995 (15 U.S.C. 272 note) because application ofthose requirements would be inconsistent with the Clean Air Act; and

15

### • does not provide the EPA with the discretionary authority to address, as appropriate, disproportionate human health or environmental effects, using practicable and legally permissible methods, under Executive Order 12898 (59 FR 7629, February 16, 1994). In addition, this rule does not have tribal implications as specified by Executive Order 13175 (65 FR 67249, November 9, 2000), because it will not impose substantial direct costs on tribal governments or preempt tribal law. The SIP is not approved to apply in Indian country located in the State, except for non-trust land within the exterior boundaries ofthe Puyallup Indian Reservation, also known as the 1873 Survey Area. Under the 

### Pu yallup Tribe of Indians SettlementAct of 1989, 25 U.S.C. 1773, Congress explicitly provided state and local agencies in Washington authority over activities on non-trust lands within the 1873 Survey Area and the EPA is therefore approving this SIP on such lands. Consistent with EPA policy, the EPA nonetheless provided a consultation opportunity to the Puyallup Tribe in a letter dated October 18, 2013. The EPA did not receive a request for consultation {Confitmj .

16

### List of Subjects in 40 CFR Part 52 Environmental protection, Air pollution control, Particulate matter, and Reporting and recordkeeping requirements. Authority: 42 U.S.C. 7401 

### et seq. Dated:

--- ----

17 

### Dennis J. McLerran Regional Administrator Region 10