March 14, 2008 

Richard A. Schutt, Chief, Air Planning Branch 

EPA Region 4 

Atlanta Federal Center 

61 Forsyth Street Southwest 

Atlanta, Georgia 30303-8909 

Re: South Carolina Fine Particulate Matter Air Quality Implementation Plan 

Dear Mr. Schutt: 

On July 18, 1997, the United States Environmental Protection Agency (EPA) promulgated new 

and revised national ambient air quality standards (NAAQS) for ozone and particulate matter 

(PM). For PM, the EPA promulgated a new 24-hour and a new annual NAAQS for PM2.5 

(particles with an aerodynamic diameter less than or equal to a nominal 2.5 mircometers). 

Under sections 110(a)(1) and (2) of the Clean Air Act (CAA), all States are required to submit 

plans to provide for the implementation, maintenance, and enforcement of the PM2.5 standard. 

Sections 110(a)(1) and (2) require States to address basic State Implementation Plan (SIP) 

requirements, including emission inventories, monitoring, and modeling to assure attainment and 

maintenance of the standard. By law, States are required to submit SIPs within three (3) years 

after promulgation of a new or revised standard. However, litigation over the 1997 8-hour ozone 

and PM2.5 NAAQS created ambiguity, and as a result, States have not submitted SIPs to meet the 

requirements enumerated in sections 110(a)(1) and (2). 

In March of 2004, Earth Justice initiated a lawsuit against the EPA for failure to take action 

against those States that had not submitted SIPs to meet the requirements of sections 110(a)(1) 

and (2). On March 10, 2005, the EPA entered into a Consent Decree with Earth Justice 

obligating the EPA to make a determination whether States have met the necessary requirements 

of sections 110(a)(1) and (2) by October 5, 2008, for PM2.5. 

On February 13, 2004, the Department submitted a request to the EPA Region 4 at the request of 

Governor Mark Sanford and on behalf of the citizens of South Carolina, that the entire state of 

South Carolina be designated as “attainment” for the aforementioned PM standards. 

On June 29, 2004, the EPA notified both the Department and the Governor’s office of its intent 

to make modifications to South Carolina’s recommendations. The EPA’s concerns focused on 

the potential for the Greenville EQC, Greenville County, monitor (AIRS #045-045-0008) to 

violate the PM2.5 standard. 
Page 2 

Mr. Schutt 

March 14,2008 

The EPA issued final designations for the PM2.5 standard on December 17, 2004. These 

designations became effective in April 2005. 

On October 2, 2007, EPA released a memorandum to the states to provide guidance on the 

"infrastructure" elements for SIPS required under section 110(a)(l) and (2) of the CAA for the 

1997 8-hour ozone and PM2.5 NAAQS. 

Electronic mail correspondence between the Department and Region 4 staff clarified that in light 

of its attainment/unclassifiable status, South Carolina need only provide a formal written letter 

certifying that the aforementioned required elements listed in the guidance memo have been 

addressed within the South Carolina Air Quality Implementation Plan. 

As outlined in the enclosed attachments to this letter, the Department is certifying to the EPA 

that the "infrastructure" elements pertaining to the PM2 5 attainmentlunclassifiable areas in South 

Carolina [as required under Section 1 10(a)(l) and (2) of the CAA] have been addressed. Should 

you have any further questions concerning South Carolina's fine particulate matter SIP 

development, please feel free to contact Maeve S. R. Mason of my staff at (803) 898-2230 or 

masonrnr@,dhec.sc.gov. 

Sincerely, 

Robert 5. Brown, Jr., Director 

Division of Air Planning, Development & Outreach 

Bureau of Air Quality 

South Carolina Department of Health and Environmental Control 

cc: Myra C. Reece, Chief, Bureau of Air Quality, SCDHEC 

Renee Shealy, Assistant Bureau Chief, Bureau of Air Quality, SCDHEC 

Manager, Regulation Development Section, SCDHEC