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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· (208) 373·0502 C.L. "Butch" Otter, Governor Toni Hardesty,· Director


### June 25, 2010 

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# r 6t?/-I -rZl(J-oA«---2_Qo-(Jl.;l'fDennis J. McLerran, Regional Administrator USEPA Region 10, MS RA-140 1200 Sixth Avenue Seattle, WA 98101
Dear Mr. McLerran: 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 11 O(a)(l) 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 PM2.5, the 200624- hour PM2

.5

, and the 1997 and 2008 8-hour ozone National Ambient Air Quality Standards. Section 110(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 nonattaimnent 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,"

P,/IlIad on Rocyclod {'aperDennis J. McLerran, Regional Administrator USEPA June 22, 20I0 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 Clean AirActSections JJO(a)(J) and 

### (2)" that Idaho submitted on September 15, 2008 with regard to Sections 1l0(a)(2)(D) and 1l0(a)(2)(G) and the 1997 armual PM2
.5, 

### the 2006 24-hour PM2
.5, 

### and the 1997 and 2008 8-hour ozone National 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 (PM2
.5) 

### 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 DivisionNOTICE 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 IIO(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: (l) attain or maintain the 1997 annual PM2
.5, the 2006 24-hour PM 2.5, 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 Air Action 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 comment process should be directed to Faye Weber, Department ofEnvironmental Quality, 1410 N. Hilton, Boise, ID 83706-1255, faye.weber@deq.idaho.gov, or (208) 373- 0440. Please reference "Interstate Transport" when sending comments or requesting information.
For technical assistance on questions concerning tins project, please contact Sue Richards at (208) 373-0502 or Sue.Richards@deq.idaho.gov. All written comments conceruing 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.Department of Environmental Quality • May 11, 2010 • For Immediate Release 

# NewsRelease

ME D I A CONTACT

• Sue Richards Air Quality Division DEQ State Office (208) 373-0502 

# DEQseekscommentonplan showingemissions from Idaho do notharm air quality in otherstates BOISE

- The Idaho Department of Environmental Quality (DEQ) is seeking public comment on aplan demonstrating that emissions from Idaho are not adversely impacting airquality in other states. The plan, entitledInterstate Transport State Implementation Plan, shows that Idaho's existing air quality State Implementation Plan and rules prohibit emissions from Idaho sources from interfering with other states' efforts to meet air quality standards and protect visibilily. The plan is snbject to approval by the U.S. Environmental ProtectionAgency (EPA). The plan is available for review at DEQ's State Office, 1410 N. Hilton, Boise, regional offices in Boise, Coeur d'Alene, Idaho Falls, Lewiston, Pocatello and Twin Falls, and in PDF format on DEQ's Web site at www.deq.idaho.govl public/comment.cfm. Fortechnical information on theplan, contact Sue Richards, DEQ Air Quality Division, at (208) 373-0502 or sue.richards@deq.idaho.gov

. The deadline for commenting on the plan is 5 p.m. MST, Thursday, June 10, 2010. Submitwritten comments electronically on DEQ's Web site or by mail oremail to: Faye Weber Air Quality Division DEQ State Office l41ON. Hilton Boise, ill 83706 Email: faye.weber@deq.idaho.gov EndDepartment of Environmental Quality • May 11, 2010 • For Immediate Release 

# NewsRelease

ME D I A CONTACT

• Sue Richards Air Quality Division DEQ State Office (208) 373-0502 

# DEQseeks commentonplan showingemissions from Idaho do notharm air quality in otherstates BOISE

- The Idaho Department of Environmental Quality (DEQ) is seeking public comment on aplan demonstrating that emissions fi'om Idaho are not adversely impacting air qnality in other states. The plan, entitledInterstate Transport State Implementation Plan, shows that Idaho's existing ail' quality State Implementation Plan and rules prohibit emissions from Idaho sources from interfering with other states' efforts to mcct air quality standards and protect visibility. Theplan is subject to approval by the U.S. Enviromnental Protection Agency (EPA). The plan is available for review at DEQ's State Office, 1410 N. Hilton, Boise, regional offices in Boise, Coeur d'Alene, Idaho Falls, Lewiston, Pocatel1o and Twin Fal1s, and in PDF format on DEQ's Web site at www.deq.idaho.govl public/comment.cfm. Fortechnicalinformationon theplan, contact Sue Richards, DEQ Air Quality Division, at (208) 373-0502 or sue.richards@deq.idaho.gov

. The deadline for commenting on the plan is 5 p.m. MST, Thursday, June 10, 2010. Submit written comments electronical1y on DEQ's Web site orby mail or email to: Faye Weber Air Quality Division DEQ State Office l4l0N.Hilton Boise, ID 83706 Email: faye.weber@deq.idaho.gov EndNOTICE OF 30-DAY PUBLIC COMMENT PERIOD AND HEARING REGARDING PROPOSAL ONINTERSTATE TRANSPORT

PROPOSED ACTION: The Depmtment 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 mmual PM2.5, the 2006 24-hour PM2
.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 Il0(a)(l) and (2). AVAILABILITY OF MATERIALS: The Interstate Transport SIP materials are available for public review on DEQ's Web site at !ill12:llwww.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 comment process should be directed to FayeWeber, Department ofEnviromnental Quality, 14l0N. Hilton, Boise, ID 83706-1255, faye.weber@deq.idaho.gov,or(208)373- 0440. Please reference "Interstate Transport" when sending comments or requesting information.
For technical assistance on questions concerning this project, please contact Sue Richards at (208) 373-0502 or Sue.Richm·ds@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, .hme 10, 2010.
DATED this 11th day ofMay, 2010.

# Updated Certification ofIdaho State Implementation Plan Adequacy Regarding Clean Air Act Sections 110(a)(1) and (2)

On September 15, 2008, Idaho submitted "Certification ofIdaho State Implementation Plan Adequac;y"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 0[7401 U.S.C. Section 2110(a)(1) and (2). This document updates that certification withregard 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 Ambient Air Quality Standards.


## Clean Air Act Section 110(a)(2)(D)
SIP Requirement: "(D) contain adequateprovisions- (i)prohibiting, cunsistent with thepruvisiuns uf this subchapter, any source or other type of emissions activity within the Statefrom emitting any airpollutant in amounts which 

### will- (I) contribute significantly to nonattainment in, or interfere with maintenance by, any other State with respect to any such nationalprimary orsecondary ambient air quality standard, or (II) interfere with measures required to be included in the applicable implementationplanjor any other State underpart C of this subchapter to prevent significant deterioration of air quality or toprotect visibility, " 

### Idaho Provisions:
Included in this submittal is Idaho's Interstate Transport SIP that replaces the SIP submitted January 30, 2007. This SIP addresses Clean Air Act (CAA) Section 110(a)(2)(D)(i)(I) and pmt ofCAA Section 110(a)(2)(D)(i)(II) with regard to prevention of significant deterioration. Idaho will submit the Regional Haze SIP sepm'ate1y 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 for authority comparable to that in section 7603 of this title and adequate 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 the requirements ofCAA Section 110(a)(2)(G) as codified in 40 CPR 51 Subpart H (Prevention ofAirPollution Emergency Episodes) and 40 CPR 51 Appendix L (Example Regulations for Prevention ofAir Pollution Emergency Episodes). Idaho's Rules are modeled on the example regulations presented in 40 CPR 51 Appendix L. Idaho's Rules apply to the entire State regardless ofregional classification (see 40 CPR 51.150) and meet all ofthe requirements listed in 40 CPR 51.152 (Contingency Plans). Table 1 lists the contingency planrequirements of40 CPR 51.152 and the Idaho rule or code that meets it. Table 2 lists the air quality criteria defining emergency episode stages for ozone and PM25, POl' stages 2 through 4, the criteria for PM2
.5and PMIO is the same (PM2.5 is a subset ofPMlO). Ozone has 3 and PM2
.5 has 7 levels (4 in Stage 1) ofcriteria that can trigger an episode stage and associated actions. Thus, Idaho meets the requirement (40 CPR 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 hann level in accordance with 40 CPR 51.151. Idaho's Rules are designed to prevent air quality anywhere in the State, without regard to regional classification, fi'om reaching significant harm levels.Table 1. Contingency Plan Crosswalk Plan Reqnirement Idaho Provision (a) Each contingency plan must- (1) Specify two or more stages ofepisode criteria such as those set fOlih in IDAPA 58.01.01.556 (see Table 2) appendix L to this part, or their equivalent; (2) Provide for public announcement whenever any episode stage has been IDAPA 58.01.01.557 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.) IDAPA 58.01.01.561 (b) Each contingency plan for a Priority I region must provide for the Idaho has no Priority I regions, following: however the following sections ofthe Rules meet these requirements: (1) Prompt acquisition offorecasts ofatmospheric stagnation conditions IDAPA 58.01.01.552.01 and ofupdates ofsuch forecasts as frequently as they are issued by the National Weather Service. IDAPA 58.01.01.121, the Inspection (2) Inspection ofsources to ascertain compliance with applicable emission and Right ofEntry authority located at control action requirements. Idaho Code Section 39-108, and the Emergency Order authority located at (3) Communications procedures for transmitting status reports and orders Idaho Code Section 39-112

as to emission control actions to be taken during an episode stage, including procedures for contact with public officials, major emission 557
sources, public health, safety, and emergency agencies and news media. (c) Each plan for a Priority IA and II region must include a contingency IDAPA 58.01.01.552.01,121, tl,e plan that meets, as a minimum, the requirements ofparagraphs (b)(1) and Inspection and Right ofEnlly (b)(2) ofthis section. Areas classified Priority III do not need to develop authority located at Idaho Code episode plans. Section 39-108, and the Emergency Order authority located at Idaho Code Section 39-112 (d) Notwithstanding the requirements ofparagraphs (b) and (c) ofthis Not applicable section, the Administrator may, at his discretion- (I) Exempt from the requirements ofthis section those pOliions ofPriority I, lA, or II regions which have been designated as attainment 01' unclassifiable for national primary and secondary standards under section 107 ofthe Act; 01' (2) Limit the requirements pertaining to emission control actions in Priority I regions to-- (i) Urbanized areas as identified in the most recent United States Census, and (ii)**M~jor** emitting facilities, as defined by section 169(1) ofU,e Act, outside the urbanized areas.Table 2. Idaho Air Quality Criteria and Associated Emergency Actions Stage Pollutant Criteria Actions I-Forecast Ozone NA There shall beno newignition ofopenburning ofany kind. and Caution PM 25 80**~m3** 1-hrave The Directormay requjre, ifpracticable, or in an emergency situation. the cessation ofany open PM 2.5 50 ).tghn' 24-hr ave burning.
PMlO 385**~m3** 1-hrave PMlO 150**~m'** 24-hr ave 2 - Alert Ozone 400 ).tglm' 1-hrave There shall be no openburning ofany kind. (0.2 ppm) The use ofbumers and incinerators for ihe disposal ofany form ofsolidwaste shall beprohibited. Persons operating fuel-burning equipment which requires boiler lancing or soot blowing shall perform PMlOIPM 2.5 350 ).tglm' 24-hr ave such operations only betweenihehours of 12:00 pm (noon) and4:00 p.m. Commercial, indUstrial and institutional facilities utilizing coal orresidual fuel oil are required to switchto natural gas or distillate oil ifavailable.
3 - Warning Ozone 800**~m'** 1-hrave There shall be no openburning ofany kind (0.4 ppm) Theuse ofbumers and incinerators for ihe disposal ofany form ofsolid waste orliquidwaste shall be prohibited. PMj(,lPM" 420 ).lg/m' 24-hr ave Persons operating fuel-burning equipmentwhichrequires boiler lancing or soot blowing shall perfonn such operations only betweenihe hours of 12:00 pm (noon) and4:00 p.m Commercial, indUstrial andinstitutional facilities utilizing coal orresidual fuel arerequiredto switch completely to natural gas or distillate oil; or ifthese low snlfur fuels are not available, curtail the use ofexisting fuels to the extent possible wiihout causing injury to persons or damage to equipment.
4- Emergency Ozone 1000 ).tglm' l-hr ave This will be called onlywith specific concurrence ofGovernor. (0.5 ppm) There shall be no openburning ofany kind.
PMlOIPM 2.5 500 ).tglm' 24-hr ave The use ofburners and incinerators for the disposal ofany form of solid orliquid waste shall be .l'rohibited.

--- _ ..•All places ofemployment described below shall immediately cease operations: i. All mining and quarrying operations; ii. All constructionwork exceptthat whichmust proceedto avoid injury to persons; iii. All manufacturing establishments exceptthose required to have inforce an airpollution emergency plan; iv. All wholesale trade establishments, i.e. places ofbusiness primarily engagedin selling merchandise to retailers orindustrial, commercial, institutional orprofessionalusers, orto other wholesalers, or acting as agents ill buying merchandise for or selling merchandise to suchpersons or companies exceptthose engagedinthe distribution ofdrngs, surgical supplies and food; v. All offices oflocal, county and State gO\remment including authorities,jointmeetings, and other public bodies excepting such agencies which are determinedby the chiefadministrative officer of local. county, or State government authorities,jointmeetings and otherpublic bodies to be vital for public safety and welfare andthe enforcement ofthe provisions ofthis order; vi. Allretail trade establishments exceptpharmacies, surgical supply distributors, and stores primarily engaged inthe sale offood; vii Banks, credit agencies otherthan banks, securities and commodities brokers, 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, shoerepair shops; ix. Advertising offices. consumer credit reporting, adjus1ment 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 exceptthose located adjacent to state orinterstate highways; xi. Establishments rendering amusement and recreational services including motionpicture theaters; 

## xu. Elementary and secondary schools, colleges, universities, professional schools,junior colleges, vocational schools, and public and private libraries.
All commercial andmanufacturing establishments not includedinthis orderwill institute such actions as willresult inmaximumreduction ofthe applicable air pollutant(s) from their operationby ceasing. curtailing, orpostponing operations which emitthe applicable airpollutants to the extentpossible 'Without causing injury to persons or damage to equipment. These actions include limiting boiler lancing or sootblowing operations for fuel burning equipment to betvveen the hours of 12:00 pm (noon) and 4:00 p.m. Whenthe emergency episode is declared for carbon monoxide, the use ofmotor vehicles is prohibited except in emergencies or '\Vith the approval oflocal or state police orthe Department.