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 Qual ity Implementation Plan

Dear Mr. Schutt:

On July 18, 1997, the United States Environmental P rotection 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 an d a new annual NAAQS for PM 2.5 (particles with an aerodynamic diameter less than o r equal to a nominal 2.5 mircometers).

Under sections 110(a)(1) and (2) of the Clean Air A ct (CAA), all States are required to submit plans to provide for the implementation, maintenanc e, and enforcement of the PM 2.5 standard. Sections 110(a)(1) and (2) require States to addres s basic State Implementation Plan (SIP) requirements, including emission inventories, monit oring, and modeling to assure attainment and maintenance of the standard. By law, States are re quired to submit SIPs within three (3) years after promulgation of a new or revised standard. H owever, litigation over the 1997 8-hour ozone and PM 2.5 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, f or PM 2.5
. On February 13, 2004, the Department submitted a re quest 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 th e aforementioned PM standards.

On June 29, 2004, the EPA notified both the Departm ent and the Governor’s office of its intent to make modifications to South Carolina’s recommend ations. The EPA’s concerns focused on the potential for the Greenville EQC, Greenville Co unty, monitor (AIRS #045-045-0008) to violate the PM 2.5 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