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STATE OF IDAHO DEPARTMENT OF ENVIRONMENTAL QUALITY 

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OFFICE OF THE EXECUTIVE

. 1410 North Hilton· Boise, Idaho 83706 D (208) 373·0502 C. L. "Butch" Olter, Governor Toni Hardesty,- Director 

### June 25, 2010

Dennis J. McLerran, Regional Administrator USEPA Region 10, MS RA-140 1200 Sixth Avenue Seattle, WA 98101 Dear Mr. McLerran: 

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### On behalfofthe State ofIdaho, the Department ofEnvironmental Quality hereby submits the following:

• Interstate Transport State Implementation Plan • Updated Certification ofIdaho State Implementation Plan Adequacy Regarding Clean Air Act Sections 110(a)(1) and (2) • News Release • Notice ofPublic Comment The Interstate Transport Plan does not revise Idaho's existing State Implementation Plan (SIP) rather it describes how Idaho's existing SIP meets the requirements ofSection 110(a)(2)(D)(i) ofthe Clean Air Act with regard to the 1997 annual PM25, the 2006 24- hour PM2.5, and the 1997 and 2008 8-hour ozone National Ambient Air Quality Standards. Section 11O(a)(2)(D)(i) provides that each state must submit a SIP that contains adequate provisions: "(i) prohibiting

... any source or other type ofemissions activity within the State from emitting any air pollutant in amounts which will (I) contribute significantly to nonattainment in, or interfere with maintenance by, any other State with respect to such national primary or secondary ambient air quality standard, or (II) interfere with measures required to be included in the applicable implementation plan for any other State under part C to prevent significant deterioration ofair quality or to protect visibility,"

Printed Gil Recycled PAperDennis J. McLerran, Regional Administrator USEPA June 22, 2010 Page 2



### The attached document explains how Idaho's current SIP and statutes meet the requirements ofSection 110(a)(2)(D)(i) with the exception ofthe requirement to protect visibility. That demonstration will be included in Idaho's Regional Haze SIP currently under Federal Land Manager review. The Updated Certification updates the "Certification of Idaho State Implementation Plan AdequacyRegarding CleanAirActSections JlO(a)(J) and (2)" that Idaho submitted on September 15, 2008 with regard to Sections 110(a)(2)(D) and 110(a)(2)(G) and the 1997 annual PM2 5, 

### the 2006 24-hour PM2 5 

### and the 1997 and 2008 8-hour ozone National

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# . Ambient Air Quality Standards. A public comment period for the Plan and Updated Certification was held May 11,2006 through June 10,2010. No comments were received during the public comment period. No public hearing was held, because Idaho meets the requirements ofSections 110(a)(I) and (2) without revising the State Implementation Plan. (See William T. Harnett's Memorandum "Guidance on SIP Elements Required Under Sections 110(a)(I) and (2) for the 2006 24-hour Fine Particle (PMzs) National Ambient Air Quality Standards (NAAQS)"). As requested, an original and two copies ofthese documents are being provided to you and your staff. Electronic copies will be provided upon request. Ifyou or your staffhave any questions concerning Idaho's submittal, please contact Sue Richards, Air Quality Analyst, DEQ Air Quality Division, at (208) 373-0586. For any questions ofa legal nature, please contact Lisa Carlson, Deputy Attorney General at (208) 373-0494. Sincerely,

Toni Hardesty Director

cc: Martin Bauer, Administrator, Air Quality Division

# Updated Certification ofIdaho State Implementation Plan Adequacy Regarding Clean Air Act Sections 110(a)(I) and (2)

On September 15, 2008, Idaho submitted "Certification ofIdaho State Implementation Plan Adequacy Regarding Clean Air Act Sections 110(a)(1) and (2)" to provide the Environmental Protection Agency (EPA) with certification that the Idaho State Implementation Plan (SIP) met the infrastructure requirements of7401 U.S.C. Section 2110(a)(1) and (2). This document updates that certification with regard to Sections 110(a)(2)(D) and 1l0(a)(2)(G) and the 1997 annual PM2 .5, the 2006 24-hoUl' PM2.5, and the 1997 and 2008 8-hour ozone National Ambient Ail' Quality Standards.


## Clean Air Act Section 110(a)(2)(D) SIP Requirement: "(D) contain adequateprovisions- (i) prohibiting, consistent with theprovisions of this subchapter, any source or other type of emissions activity within the State from emitting any airpollutant in amounts which will- (I) contribute significantly to nonattainment in, or**inte~rere** with maintenance by, any other State with respect to any such nationalprimary or secondary ambient air quality standard, or (II) interfere with measures required to be included in the applicable implementationplan for any otherState underpart C of this subchapter to preventsignificant deterioration of air quality or toprotect visibility, " 

### Idaho Provisions: Included in this submittal is Idaho's Interstate TranspOli SIP that replaces the SIP submitted

... January 30, 2007. This SIP adch'esses Clean Ail' Act (CAA) Section 110(a)(2)(D)(i)(I) and pmi ofCAA Section 11 0(a)(2)(D)(i)(II) with regard to prevention ofsignificant deterioration. Idaho will submit the Regional Haze SIP sepm'ately due to differing notice and comment requirements. That submittal will address the remainder ofCAA Section 110(a)(2)(D)(i)(II).

## Clean Air Act Section 110(a)(2)(G) SIP Requirement: "(G)provide jor authority comparable to that in section 7603 of this title andadequate contingencyplans to implementsuch authority;" 

### Idaho Provisions: Emergency Order authority comparable to Section 303 ofthe Clean Air Act is located at Idaho Code Section 39-112. Idaho's Air Pollution Emergency Rules (Rules) (IDAPA 58.01.01.550 through 562) meet therequirements ofCAA Section 110(a)(2)(G) as codified in 40 CFR 51 Subpart H (Prevention ofAir Pollution Emergency Episodes) and 40 CFR 51 Appendix L (Example Regulations for Prevention ofAir Pollution Emergency Episodes). Idaho's Rules are modeled on the example regulations presented 

### in 40 CFR 51 Appendix L. Idaho's Rules apply to the entire State regardless ofregional classification (see 40 CFR 51.150) and meet all ofthe requirements listed in40 CFR 51.152 (Contingency Plans). Table 1 Iists the contingency plan requirements of40 CFR 51.152 and the Idaho rule or code that meets it. Table 2 Iists the air quality criteria defining emergency episode stages for ozone and PM2.5. For stages 2 through 4, the criteria for PM2

.5and PMIO is the same (PM2.5 is a subset ofPMlO). Ozone has 3 and PM2., has 7 levels (4 in Stage 1) ofcriteria that cantrigger an episode stage and associated actions. Thus, Idaho meets the requirement (40 CFR 51.152(a)(I)) for two or more stages ofepisode criteria for ozone and PM2.5 . Idaho has no Priority I regions and is not required to establish a significant harm level 

### in accordance with 40 CFR 51.151. Idaho's Rules are designed to prevent air quality anywhere 

### in the State, without regard to regional classification, from reaching significant harm levels.Table 1. Contingency Plan Crosswalk Plan Reqnirement (a) Each contingency plan must- (1) Specify two or more stages ofepisode criteria such as those set forth in appendix L to this part, or their equivalent; (2) Provide for public announcement whenever any episode stage has been determined to exist; and (3) Specify adequate emission control actions to be taken at each episode stage. (Examples ofemission control actions are set forth in appendix L.) (b) Each contingency plan for a Priority I region must provide for the following: (1) Prompt acquisition offorecasts ofatmospheric stagnation conditions and ofupdates of such forecasts as frequently as they are issued by the National Weather Service. (2) Inspection ofsources to ascertain compliance with applicable emission control action requirements. (3) Communications procedures for transmitting status reports and orders as to emission control actions to be taken during an episode stage, including procedures for contact with public officials, major emission sources, public health, safety, and emergency agencies and news media. (c) Each plan for a Priority IA and IT region must include a contingency plan that meets, as a minimum, the requirements ofparagraphs (b)(1) and (b)(2) ofthis section. Areas classified Priority IT! do not need to develop episode plans.
(d) Notwithstanding the requirements ofparagraphs (b) and (c) ofthis section, the Administrator may, at his discretion- (1) Exempt from the requirements ofthis section those portions ofPriority I, lA, 01' II regions which**~ave** been designated as attainment or unclassifiable for national primary and secondary standards under section 107 ofthe Act; 01' (2) Limit the requirements pertaining to emission control actions in -Pl;iodfiI regions-to=.:

---- ---- (i) Urbanized areas as identified in the most recent United States Census, and Oi) Major emitting facilities, as definl'd by section 169(1) ofthe Act, outside the urbanized areas. Idaho Provision

IDAPA 58.01.01.556 (see Table 2)

IDAPA 58.01.01.557

IDAPA 58.01.01.561 Idaho has no Priority I regions, however the following sections oftile Rules meet these requirements: IDAPA 58.01.01.552.01 IDAPA 58.01.01.121, the Inspection and Right ofEntry authority located at Idaho Code Section 39-108, and tl,e Emergency Order authority located at Idaho Code Section 39-112 557

IDAPA 58.01.01.552.01,121, the Inspection and Right ofEntry authority located at Idaho Code Section 39-108, and the Emergency Order authority located at Idaho Code Section 39-112 Not applicable

### Table 2. Idaho Air Quality Criteria and AssociatedEmergency Actions Stage Pollutant Criteria Actions I-Forecast Ozone NA There shall beno newignition ofopenburning ofany kind. and Caution PM 2.5 80**~gIm3** I-hr ave The Directormay require, ifpracticable, orin an emergency**situatio~** the cessation ofany open PM 25 50**~gIID3** 24-hr ave burning. PMlO 385**~m3** I-hr ave PMlO ISO**~o;Im3** 24-hr ave 2 - Alert Ozone 400**~m3** J-hr ave There sball beno openburning ofany kind. (0.2 ppm) Theuse ofbumers andincinerators for the disposal ofany form ofsolid waste shall beprohibited. Persons operating fuel-burning equipment whichrequires boiler lancing or sootblowing shall perfonn PMl<Y'PMZ5 350**~m3** 24-hr ave such operations only between the hours of 12:00 pm (noon) and4:00 p.m. Commercial, industrial and institutional facilities utilizing coal orresidnal fuel oil are required to switch to natural gas or distillate oil ifavailable.
3 - Warning Ozone 800**~ID31-hrave** There sball beno openburning ofany kind (0.4 ppm) Theuse ofbumers andincinerators for the disposal ofany form ofsolid waste orliquidwaste shall be prohibited. PM,ofPM25 420**~gIID3** 24-hr ave Persons operating fuel-burning equipment whichrequires boiler lancing or sootblowing shall perfonn such operations only betweenthe hours of 12:00 pm (noon) and4:00 p.m Commercial, industrial and institutional facilities utilizing coal orresidual fuel are required to switch completely to natural gas or distillate oil; or ifthese low snlfur fuels are not available, curtail the use ofexisting fuels to the extentpossible Vlithout causing injury to persons or damage to equipment. 4- Emergency Ozone 1000**~m3** I-hr ave This mil be called only with specific concurrence ofGovernor. (0.5 ppm) There shall be no openburning of any kind. PM,ofPM23 500**~gIm3** 24-hr ave The use ofbumers andincinerators for the disposal ofany fonn of solid orliquid waste shall be jJT()bibited.Allplaces ofemployment describedbelow shall immediately cease operations: i. All mining and quarrying operations; ii All construction work except that which mustproceed to avoid injury to persons; iii. All manufacturing establishments exceptthose requiredto have inforce an air pollution emergency plan; iv. All wholesale trade establishments, i.e. places ofbusiness primarily engagedin selling merchandise to retailers orindustrial, commercial, institutional or professional users, orto oilier wholesalers, or acting as agents inbuying merchandise for or selling merchandise to suchpersons orcompanies except those engaged in the distribution ofdrugs, surgical supplies andfood; v. All offices oflocal, county and State government including authorities,jointmeetings, and other public bodies excepting such agencies which are determined by fue chiefadministrative officer of local, county, or State government authorities,jointmeetings and otherpublic bodies to be vital for public safety and welfare andfue enforcement offue provisions ofthis order; vi. Allretail trade establishments except pharmacies, surgical supply distributors, and stores primarily engaged inthe sale offood; vii. Banks, credit agencies otherthan banks, securities and commoditiesbrokers, dealers, exchanges and services; offices ofinsurance carriers, agents andbrokers, real estate offices; viii. 'Wholesale andretail laundries, laundry services and cleaning and dyeing establishments; photographic studios; beauty shops, barber shops, shoe repair shops; ix. Advertising offices, consumer creditreporting, adjustment and collection agencies; duplicating, addressing, blueprinting; photocopying, mailing, mailing list and stenographic services; equipment rental services, commercial testing laboratories; x. Automobile repair, automobile services, garages except those located adjacent to state or interstate highways; xi. Establishments rendering amusement and recreational services including motionpicture theaters; xii. Elementary and secondaty schools, colleges, universities, professional schools,junior colleges, vocational schools, andpublic andprivate libraries. All commercial andmanufacturing establishments not included inthis order will institute such actions as willresult inmaxinmmreduction ofthe applicable

## orr pollutant(s) fromtheir operationby ceasing, curtailing, orpostponing operations which emit the applicable air pollutants to the extentpossible without causinginjury to persons ordamage to equipment. These actions include limiting boiler lancing or sootblowing operations for fuel burning equipment to betweenthe hours of 12:00 pm (noon) and4:00 p.m Whenthe emergency episode is declared for carbonmonoxide, the use ofmotor vehicles is prohibited exct::pt inemergencies or withthe approval oflocal or state police orthe Department.NOTICE OF 30-DAY PUBLIC COMMENT PERIOD AND HEARING REGARDING PROPOSAL ON INTERSTATE TRANSPORT

PROPOSED ACTION: The Department ofEnvironmental Quality (DEQ) is proposing to submit a State Implementation Plan (SIP) to the Environmental Protection Agency (EPA) demonstrating that Idaho's existing SIP provisions, rules, and emissions meet the requirements ofSection 110(a)(2)(D)(i) ofthe Clean Air Act. Idaho is required to demonstrate that interstate transport ofemissions from Idaho will not interfere with any other state efforts to: (1) attain or maintain the 1997 annual PM Z,5, the 2006 24-hour PM Z

,5, and the 1997 and 2008 8-hour ozone National Ambient Air Quality Standards, (2) prevent significant deterioration ofair quality, or (3) protect visibility.

, Idaho is also updating its Certification ofIdaho State Implementation Plan Adequacy

Regarding Clean AirAction Sections IIO(a)(I) and (2). AVAILABILITY OF MATERIALS: The Interstate Transport SIP materials are available for public review on DEQ's Web site at http://www.deq.idaho.gov.Printed materials will be made available upon request at any ofthe regional offices in Coeur d'Alene, Lewiston, Boise, Twin Falls, Pocatello, and Idaho Falls. SUBMISSION OF WRITTEN COMMENTS-ASSISTANCE ON TECHNICAL OUESTIONS: Anyone may submit written comment regarding this proposal. To be most effective, comments should address air quality considerations and include support materials where available. Comments, requests, and questions regarding the public commentprocess should be directed to Faye Weber, Department ofEnvironmental Quality, 1410N. Hilton, Boise, ID 83706-1255, faye.weber@deq.idaho.gov, or (208) 373- 0440. Please reference "Interstate Transport" when sending comments or requesting information. Fortechnical assistance on questions concerning this project, please contact Sue Richards at (208) 373-0502 or Sue.Richards@deq.idaho.gov. All written comments concerning this proposal must be directed to and received by the undersigned on or before 5:00, p.m., MST/MDT, June 10,2010. DATED this 11th day ofMay, 2010.