UNITED STATES ENVIRONMENTAL. PROTECTION AGENCY

REGION 10

1200 Sixth Avenue, Suite 900

Seattle, WA 98101-3140

APR 05 2013 OFFICE OF

AIR, WASTE AND TOXICS

Stu Clark, Air Quality Program Manager

Washington State Department of Ecology

PO Box 47600

Olympia, WA 98504-7600

Fran McNair, Executive Director

Olympic Region Clean Air Agency

2940 Limited Lane, Suite B

Olympia, WA 98502

Re: Review of Draft Thurston County Second 10-Year Limited Maintenance Plan

Dear NJ rCTark and Ms air:

We have reviewed the draft "SIP Revision for the Thurston County, Washington Second

10-Year Limited Maintenance Plan for PM to" to identify potential deficiencies prior to your

local and state public comment process. When compared with current EPA policy and

requirements, we have concluded that the draft version last revised March 6, 2013, would likely

be approvable into the Washington State Implementation Plan. However, the EPA. will make a

final decision based on our review of the complete State Implementation Plan that is submitted

following your public process and after consideration of any comments we receive as part of the

Enviromnental Protection Agency public process.

If you have any questions please feel free to contact me at 206-553-1271 or have your

staff contact either Debra Suzuki, Air Programs Unit Manager, at 206-553-0985 or Jeff Hunt,

staff lead, at 206-553-0256.

Kati (e ly, ► tor

Office of ' ste, and Toxics

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 10

1200 Sixth Avenue, Suite 900

Seattle, WA 98101-3140

OFFICE OF

AIR. WASTE AND TOXICS

March 7, 2013

MEMORANDUM

SUBJECT: Review of Draft Thurston County Second 10-Year Limited Maintenance Plan for

PM10

FROM: Jeff Hunt, Air Quality Planner

TO: Debra Suzuki, Air Programs Unit Manager

The Washington Department of Ecology (Ecology) and Olympic Region Clean Air Agency

(ORCAA) asked EPA Region 10 to review the draft "SIP Revision for the Thurston County,

Washington Second 10-year Limited Maintenance Plan for PM 10" so that any errors or EPA

concerns can be addressed prior to the start of the public comment period. Barring significant

changes as a result of public comment, Ecology intends to submit a finalized version of this draft

for EPA approval into the Washington State Implementation Plan (SIP).

I coordinated my review with Robert Kotchenruther, from the Office of Environmental

Assessment. Generally speaking, the draft Thurston County plan easily meets the criteria for a

limited maintenance plan approval. Listed below are the three main criteria to qualify for a

limited maintenance plan as they relate to the Thurston County plan.

1. The area must be attaining the NAAQS --- Thurston County attained the PM 10 standard in

1991 and has been in compliance with the PM 10 standard ever since. EPA redesignated the

area to attainment as part of an October 4, 2000 maintenance plan approval (65 FR 59128).

2. The average 24-hour PM 10 design value for the area based on the most recent five years of

data should not exceed 98 Lg/m3 the most recent design value estimate using 2008 to 2012

data is 45 pg/m3 . A more detailed discussion of the monitoring data is included below.

3. .The area should expect only limited growth in on-road motor vehicle PM 1D emissions and

should have passed a motor vehicle regional emissions analysis test - the calculated Regional

Emissions Analysis Margin of Safety for mobile source contribution was 62 }Lglm3 . This

value is well below the 98 }Lg/n13 limit showing that PM 10 emissions from on-road motor

vehicle growth will be minimal.

In addition to the limited maintenance plan criteria above, Ecology and ORCAA requested

several updates to the SIP as part of the draft revision package. I reviewed the proposed changes

and believe that they would strengthen and update the SIP if submitted. A discussion of each of

the changes is included below.
Approval of an alternate method for monitoring PM i o in Thurston County

In order to focus resources on more pressing fine particulate matter (PM 2,5) concerns, EPA

approved discontinuation of the Federal Reference Method PMIO monitor as part of the 2007

Monitoring Network Report approval process. This decision was supported by two factors: 1.)

PMIo values at that time were well below the standard, with an average 24-hour PM I o design

value equal to 60 tg/m3 for the 2001-2005 monitoring period; and 2.) a nephelometer collocated

at the site was providing accurate PKo monitoring data consistent with the Federal Reference

Method monitor. This 2 "`I 10-year maintenance plan submission is EPA's first opportunity to

approve the alternate monitoring method into the SIP. After reviewing the correlation data

between the two monitors, I agree with the determination that the nephelometer is accurately

measuring PMIo values and recommend approval of this monitoring method for the 2"d 10-year

maintenance period. PM Io levels continue to drop with the most recent estimated design value

for 2008-2012 equal to 45 lg/rn 3 . Given these low levels compared to the 150 p.g/m3 NAAQS

standard, any minor differences between the two monitoring methods is likely to be moot as

discussed below.

A transition from PMIo to PM2 ,5 control measures

The Thurston County attainment plan approved by EPA in 1993 relied on three control strategies

we still use today for particulate matter:

• Curtailment of wood burning devices during periods of impaired air quality

• Certification of new wood burning devices

• Rules governing the sale and removal of uncertified wood stoves

Today, however, we are far more concerned with the more stringent and environmentally

relevant PM2.5 24-hour standard of 35 l.ig/m3 . Based on data from the Thurston County monitor,

PM2,5 levels would need to reach 139 μg/m3 to violate the PM Io standard on a typical winter clay

of concern. For this reason, the control measures listed above now focus on PM2,5 curtailment

programs.

This draft revision contains ORCAA regulations for incorporation into the SIP based on more

recent PM2,5 trigger levels to supplement the control measures last approved into the SIP in 1993.

A comparison of the ORCAA rules with the 1993 SIP approved rules is included as Attachment

A.

An update to the SIP approved Ecology rules

Ecology's Solid Fuel Burning Device Standards, chapter 173-433 Washington Administrative

Code (WAC), were last approved into the SIP on January 15, 1993, based on regulations from

1987, 1989, and 1990. Ecology subsequently revised portions of chapter 173-433 WAC which

would significantly strengthen the SIP, including one of the nation's most stringent emissions

2
performance standard. Incorporation of these revised sections is the first step in our collective

effort to bring the SIP up to date for solid fuel burning devices. A redline strikeout version of the

submitted 1991 and 1993 Ecology rule changes compared to the SIP approved provisions is

included as Attachment B along with my analysis.

Removal of WAC 173-433-170 Retail sales fee from the SIP

Ecology requested that EPA remove WAC 173-433-170 Retail sales fee from the SIP. While the

November 1991Thurston County attainment plan does include a copy of all regulatory changes

to chapter 173-433 WAC, including WAC 173-433-170, inclusion of the retail sales fee is not

necessary as part of the SIP since it was not a control measure relied on for attainment in the

plan. Therefore, I recommend removing this provision from the federally enforceable SIP.

Creation of a sample proposed Federal Register notice

In order to identify all relevant issues to the best of my ability, I drafted a sample Federal

Register notice based on the Sandpoint PMIO Nonattainment Area Limited Maintenance Plan

and Redesignation Request recently signed by Dennis McLerran on January 22, 2013. This

sample Federal Register notice is included ,as Attaclanent C. The sample is intended to identify

any issues with Ecology's draft. Upon submission, I will review any changes to Ecology's final

SIP revision along with any comments received during the state or local public comment periods,

and revise this draft as appropriate.

3
Attachment A - Comparison of ORCAA Regulations to Existing SIP Provisions

ORCAA Rule 6.2.3 No residential or land clearing burning is allowed in the following cities

and/or UGAs:

lallam Grays

Harbor

rib-ow Ala cl'e m

aiIarr y Ro ui r

art 5

Thurston

ORCAA Rule 6.2.6 Curtailment

(a) No outdoor fire shall be ignited in a geographical area where a burn ban has been declared.

(b) The person responsible for an outdoor fire must extinguish the fire when a burn ban is

declared.

(c) Three (3) hours after a burn ban is declared smoke visible from all types of outdoor burning,

except land clearing burning, will constitute prima facie evidence of unlawful outdoor burning.

(d) Eight (8) hours after a burn ban is declared smoke visible from land clearing burning will

constitute prima facie evidence of unlawful outdoor burning.

Rule 6.2.7 Recreational Burning

The following burn practices shall be used for recreational burning where allowed.

(a) Maximum pile size is three (3) feet in diameter and two (2) feet high. (WAC 173-425-060)

(b) Only dry, seasoned firewood or charcoal and enough clean paper necessary to start a fire may be

burned.

(c) No recreational bites are allowed within the city limits of Lacey; Olympia; and Tumwater, and

unincorporated areas of Thurston County lying within or between the municipal boundaries of these

cities. Charcoal, propane, or natural gas may be used without a permit.

Existing SIP - WAC 173-425-036 CURTAILMENT DURING EPISODES OR IMPAIRED

AIR QUALITY

(1) No open fire shall be ignited:

(a) Whenever ecology has declared an air pollution episode for the geographical area pursuant to

chapter 173-435 WAC; or

(b) Whenever ecology or an authority has declared impaired air quality for the geographical area.

4
(2) A person responsible for an open fire at the time an episode or impaired air quality is

declared shall extinguish that fire. Open fires conducted under the auspices of the department of

natural resources for the purpose of burning forest slash pursuant to RCW 70.94.660 through

70.94.700 are to be extinguished by withholding new fuel and allowing the fire to burn down.

(3) Smoke visible from a small fire after a time period of three hours has elapsed from the time

of declaration of the episode or impaired air quality shall constitute prima facie evidence of

unlawful open burning.

(4) Smoke visible from a fire other than a small fire after a time period of ten hours has elapsed

from the time of declaration of the episode or impaired air quality shall constitute prima facie

evidence of unlawful open burning.

(5) Ecology, air authorities, health departments, fire departments, or local police forces having

jurisdiction in the area may enforce compliance with the above open burning curtailment rules.

State adopted: 10/18/90; EPA effective: 1/15/93

EPA Analysis - The ORCAA regulations are as stringent, if not more stringent, than the existing

SIP provisions.

ORCAA Rule 8-l..l Definitions

"Adequate Source of Heat" means a furnace or heating system, connected or disconnected from

its energy source, designed with the ability to maintain seventy degrees Fahrenheit (70°F) at a

point three (3) feet above the floor in all normally inhabited areas of a dwelling. Garages are

specifically excluded.

"Certified" means that a woodstove meets emission performance standards when tested by an

accredited independent laboratory and labeled according to procedures specified by EPA in 40

CFR Part 60 Subpart AAA-Standards of Performance for Residential Wood Heaters as amended

through July 1, 1990.

"Cook Stove" means an appliance designed with the primary function of cooking food and

containing an integrally built-in oven, with an internal temperature indicator and oven rack,

around which. the fire is vented, as well as a shaker grate ash pan, and an ash cleanout below the

firebox. Any device with a fan or heat channels used to dissipate heat into the room shall not be

considered a cook stove.

"Fireplace" means a permanently installed masonry fireplace; or a factory-built metal solid fuel

burning device designed to be used with an open combustion chamber and without features to

control the air to fuel ratio.

"First Stage of Impaired Air Quality" means the same as Stage 1 burn ban and is declared when

meteorological conditions are predicted to cause fine particulate levels to exceed 35 micrograms

per cubic meter measured on a 24 hour average, within 48 hours.

"Second Stage of Impaired Air Quality" means the same as Stage 2 burn ban and 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 (RCW 70.94.473). A second stage burn ban may be

5
called without calling a first stage burn ban only when all of the following occur (RCW

70.94.473(c)(ii)):

(a) Fine particulate levels have reached or exceeded 25 micrograms per cubic meter, measured

on a 24 hour average:

(b) Meteorological conditions have caused fine particulate levels to rise rapidly;

(c) Meteorological conditions are predicted to cause fine particulate levels to exceed the 35

micrograms per cubic meter, measured on a 24 hour average, within 24 hours; and,

(d) Meteorological conditions are highly likely to prevent sufficient dispersion of fine

particulate.

"Nonaffected Pellet Stove" means that a pellet stove has an air-to-fuel ratio equal to or greater

than 35.0 when tested by an accredited laboratory in accordance with methods and procedures

specified by the EPA in 40 CFR Part 60 Appendix A, Reference Method 28A-Measurment of

Air to Fuel Ratio and minimum achievable burn rates for wood fired appliances as amended

through July 1, 1990.

"Salt Laden Wood" means any species of wood that has been soaked in salt water.

"Seasoned Wood" means clean, untreated wood of any species that has been sufficiently dried so

as to contain twenty percent (20%) or less moisture by weight.

"Solid Fuel Burning Device" means a device that burns seasoned wood, coal, or any other

nongaseous or nonliquid fuels except those prohibited by Rule 8.1.3. This also includes devices

used for aesthetic or a space heating purpose, which has a heat input less than one million British

thermal units per hour. A cook stove is specifically excluded from this definition.

"Treated Wood" mean wood of any species that has been chemically impregnated, painted, or

similarly modified to improve structural "qualities or resistance to weathering or deterioration.

"Woodstove." means an enclosed solid fuel burning device capable of and intended for space

heating and/or domestic water heating.

Existing SIP --- WAC 173-433-030 DEFINITIONS.

The definitions of terms contained in chapter 173-400 WAC are incorporated by reference.

Unless a different meaning is clearly required by context, the following words and phrases as

used in this chapter, shall have the following meanings:

(1) "Adequate source of heat" means the ability to maintain seventy degrees Fahrenheit at a point

three feet above the floor in all normally inhabited areas of a dwelling.

(2) "Certified" means that a woodstove meets emission performance standards when tested by an

accredited independent laboratory according to EPA or DEQ procedures.

(3) "Coal-only heater" means an enclosed, coal burning appliance capable of and intended for

residential space heating, domestic water heating, or indoor cooking, which has all of the

following characteristics:

(a) An opening for emptying ash which is located near the bottom or the side of the appliance;

(b) A system which admits air primarily up and through the fuel bed;

(c) A grate or other similar device for shaking or disturbing the fuel bed or power driven

mechanical stoker; and

6
(d) The model is listed by a nationally recognized safety testing laboratory for use of coal only,

except for coal ignition purposes.

(4) "Dealer" means a person other than a manufacturer or a retailer who is engaged in selling

solid fuel burning devices to retailers or others for resale.

(5) "DEQ" means Oregon department of environmental quality.

(6) "EPA" means United States Environmental Protection Agency.

(7) "Impaired Air Quality" means a condition declared by ecology or an authority whenever:

(a) Meteorological conditions are conducive to an accumulation of air contamination concurrent

with:

(i) Total suspended particulate at an ambient level of one hundred twenty-five micrograms per

cubic meter measured on a twenty-four hour average; or

(ii) Particulate that is ten micron and smaller in diameter (PM10) at an ambient level of ninety

micrograms per cubic meter measured on a twenty-four hour average; or

(iii) Carbon monoxide at an ambient level of eight parts of contaminant per million parts of air

by volume (ppm) measured on an eight-hour average; or

(b) Air quality reaches other limits established by ecology or an authority.

(8) "Manufacturer" means any person who constructs or imports a solid fuel burning device or

parts for a solid fuel burning device.

(9) "New Woodstove" means a woodstove that has not been sold at retail, bargained, exchanged,

or given away for the first time by the manufacturer, the manufacturer's dealer or agency, or a

retailer, and has not been so used as to become what is commonly known as "second hand"

within the ordinary meaning of that term.

(10) "Retailer" means any person engaged in the sale of solid fuel burning devices directly to the

public. A contractor who sells dwellings with solid fuel burning devices installed or a mail order

outlet which sells solid fuel burning devices directly to the public is considered to be a solid fuel

burning device retailer.

(11) "Seasoned wood" means wood of any species that has been sufficiently dried so as to

contain twenty percent or less moisture by weight.

(12) "Solid fuel burning device" (same as solid fuel heating device) means a device that burns

wood, coal, or any other nongaseous or nonliquid fuels, and includes any device burning any

solid fuel except those prohibited by WAC 173-433-120. This also includes devices used for

aesthetic or space-heating purposes in a private residence or commercial establishment, which

has a heat input less than one million British thermal units per hour.

(13) "Treated wood" means wood of any species that has been chemically impregnated, painted,

or similarly modified to prevent weathering, deterioration, and damage due to insects.

(14) "Woodstove" (same as "wood heater") means an enclosed solid fuel burning device capable

7
of and intended for residential space heating and domestic water heating that meets the following

criteria:

(a) For the purposes of determining qualification under Oregon Administrative Rules, Chapter

340, Division 21 - Woodstove Certification - dated November 1984: An air-to-fuel ratio in the

combustion chamber less than 30.0 during the burning of ninety percent or more of the fuel mass

consumed in the low firing cycle. The low firing cycle means less than or equal to twenty-five

percent of the maximum burn rate achieved with the doors closed or the minimum burn rate

achievable, whichever is greater; or

(b) For the purposes of determining qualification under 40 CFR 60 Subpart AAA - Standards of

Performance for Residential Wood Heaters - dated February 26, 1988:

(i) An air-to-fuel ratio in the combustion chamber averaging less than 35.0, as determined by

EPA Reference Method 28A;

(ii) A useable firebox volume of less than twenty cubic feet;

(iii) A minimum burn rate less than 5kg/hr as determined by EPA Reference Method 28;

(iv) A maximum weight of 800 kg, excluding fixtures and devices that are normally sold

separately, such as flue pipe, chimney, and masonry components not integral to the appliance.

EPA Analysis --- The ORCAA regulations are a significant improvement over the existing SIP

provisions last approved by EPA in 1993. The ORCAA rules contain trigger levels for PM2.5

and contain updated certification standards.

ORCAA Rule 8.1.2 General Emission Standards

(a) No person .. ,. --' en-from a solid fue-l-hurning-de 4ee that.

unre. and-enjoyment of property or-workplace:

(b) No person shall cause or allow emission of a smoke plume from any solid fuel burning

device to exceed an average of twenty percent (20%) opacity as determined by EPA Method 9.

The provision of this requirement shall not apply during the starting of a new fire for a period not

to exceed 20 minutes in any 4 hour period.

(c) Smoke visible from a chimney, flue, or exhaust duct, in excess of the opacity standard shall

constitute prima facie evidence of unlawful operation of an applicable solid fuel burning device.

This presumption may be refuted by demonstration that the smoke was not caused by an

applicable solid fuel burning device.

Existing SIP -- WAC 173-433-110 OPACITY STANDARDS.

(1) Phase 1 opacity level. A person shall not cause or allow emission of a smoke plume from any

solid fuel burning device to exceed an average of forty percent opacity for six consecutive

minutes in any one-hour period.

8
(2) Phase 2 opacity level. After July 1, 1990, a person shall not cause or allow emission of a

smoke plume form any solid fuel burning device to exceed an average of twenty percent opacity

for six consecutive minutes in any one hour period.

(3) State-wide opacity standard. An authority shall not adopt or enforce an opacity level for solid

fuel burning devices that is more stringent than the state-wide standard.

(4) Test method and procedures. EPA reference method 9 - Visual Determination of the Opacity

of Emissions from Stationary Sources shall be used to determine compliance with subsections

(1) and (2) of this section.

(5) Enforcement. Smoke visible from a chimney, flue or exhaust duct in excess of the opacity

standard shall constitute prima facie evidence of unlawful operation of an applicable solid fuel

burning device. This presumption may be refuted by demonstration that the smoke was not

caused by an applicable solid fuel burning device. The provisions of this requirement shall:

(a) Be enforceable on a complaint basis.

(b) Not apply during the starting of a new fire for a period not to exceed twenty minutes in any

four-hour period.

EPA Analysis -- While the wording of the ORCAA Rule 8.1.2 is different than the existing

SIP language the overall stringency of the opacity standard is the same. ORCAA is not

seeking approval of Rule 8.1.2(a) into the SIP since it is unrelated to the opacity standard.

ORCAA Rule 8 l.3 Prohibited Fuel Types

A person shall not cause or allow any of the following materials to be burned in a solid fuel

burning device:

(a) Garbage;

(b) Treated wood;

(c) Plastic products;

(d) Rubber products;

(e) Animals;

(f) Asphalt products;

(g) Petroleum products;

(h) Paints and chemicals;

(i) Salt laden wood; or

(j) Any substance that normally emits dense smoke or obnoxious odors.

9
Existing SIP -- WAC 173-433-120 PROHIBITED FUEL TYPES.

A person shall not cause or allow any of the following materials to be burned in a solid fuel

burning device:

(1) Garbage;

(2) Treated wood;

(3) Plastic and plastic products;

(4) Rubber products;

(5) Animal carcasses;

(6) Asphaltic products;

(7) Waste petroleum products;

(8) Paints and chemicals; or

(9) Any substance other than paper to start the fire, properly seasoned fuel wood, or coal with

sulfur content less than 1.0% by weight burned in a coal-only heater, which normally emits

dense smoke or obnoxious odors.

State adopted: 10/18/90; EPA effective: 1/15/93

EPA Analysis - The ORCAA rules are nearly identical to the existing SIP provisions.

Arguably, the ORCAA provisions are more stringent since they limit the burning of all

petroleum products rather than just waste petroleum products, as well as prohibiting the

burning of salt laden wood.

ORCAA Rule 8.1.4 Curtailment

(a) Whenever the Agency has declared a Stage I burn ban for a geographic area, a person within

that geographic area with an adequate source of heat other than a solid fuel burning device shall

not operate any solid fuel burning device, unless the solid fuel burning device is one of the

following:

(I) Certified; or

(2) A nonaffected pellet stove.

(b) Whenever the Agency has declared a Stage 2 burn ban for a geographic area, a person within

that geogrttpliical-area with ail adequate source of heat other- than a solid fuel burning: device

shall not operate any solid fuel burning device.

(c) The affected geographic area of a declared Impaired Air Quality shall be determined by the

Executive Director or their designee.

(d) A person responsible for an applicable solid fuel burning device already in operation at the

time Impaired Air Quality is declared shall withhold new solid fuel for the duration of the

Impaired Air Quality. Smoke visible from a chimney, flue, or exhaust duct after three hours has

elapsed from the declaration of the Impaired Air Quality shall constitute prima facie evidence of

unlawful operation of an applicable solid fuel burning device. This presumption may be refuted

by demonstration that the smoke was not caused by a solid fuel burning device.

(e) For the sole purpose of a contingency measure to meet the requirements of Section 172(c)(9)

of the Federal Clean Air Act, the use of solid fuel burning devices, except fireplaces as defined

in RCW 70.94.453(3), woodstoves meeting the standards set forth in RCW 70.94.457 or pellet

stoves either certified or issued an exemption by the EPA in accordance with Title 40, Part 60 of

.10
the Code of Federal Regulations will be prohibited if the EPA, in consultation with Ecology and

the Agency, makes written findings that:

(1) The area has failed to make reasonable further progress or attain or maintain a national

ambient air quality standard; and,

(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.

(3) A prohibition issued under 8.1.4(e) shall not apply to a person that does not have an adequate

source of heat without burning wood.

(4) The area is to consist of all areas within the city limits of Lacey, Olympia, and Turnwater and

unincorporated areas of Thurston County lying within or between the municipal boundaries.

Existing SIP -- WAC 173-433-150 CURTAILMENT.

(1) A person in a residence or commercial establishment with an adequate source of heat other

than the burning of solid fuel shall not burn solid fuel in any solid fuel burning device:

(a) Whenever ecology has declared an air pollution episode for the geographical area pursuant to

chapter 173-435 WAC; or

(b) Whenever ecology or an authority has declared impaired air quality for the geographical area,

except when the solid fuel burning device is certified under WAC 173-433-100.

(2) A person responsible for a solid fuel burning device already in operation at the time an

episode is declared shall withhold new solid fuel for the duration of the episode. A person

responsible for a solid fuel burning device that is not certified under WAC 173-433-100 already

in operation at the time impaired air quality is declared shall withhold new solid fuel for the

duration of the impaired air quality. Smoke visible from a chimney, flue or exhaust duct after

three hours has elapsed from the declaration of the episode or impaired air quality shall

constitute prima facie evidence of unlawful operation of an applicable solid fuel burning device.

This presumption may be refuted by demonstration that the smoke was not caused by a solid fuel

burning device.

(3) Ecology, authorities, health departments, fire departments, or local police forces having

jurisdiction in the area may enforce compliance with the above solid fuel burning device

curtailment rules after three hours has elapsed from the declaration of the episode or impaired air

quality.

State adopted: 10/18/90; EPA effective: 1/15/93

EPA Analysis - Although the wording of the ORCAA rule is different than the existing SIP

language the overall stringency and effectiveness of the rule appears to be equivalent. The

ORCAA rule also contains the area specific contingency measure for the Thurston County

maintenance area.

11
ORCAA Rule 8.1.5 Exemptions

Written exemptions granted by the Agency shall be valid for one (1) year from date of issue.

Exemptions may be canceled at any time if the original request is found to be incorrect,

inaccurate or fraudulent. Exemptions shall apply only to the use of solid fuel burning device

during an Impaired Air Quality and not to the other rules of this regulation or other applicable

regulations.

(a) Emergency exemption. In an emergency situation the Agency may issue a written solid fuel

burning device emergency exemption. An emergency situation shall include, but is not limited

to, a situation where a person demonstrates that their heating system, other than a solid fuel

heating device, is inoperable for reasons other than their own actions or a situation where the

heating system has been involuntarily disconnected by a utility company or other fuel supplier.

(b) Inadequate heat source. Written exemptions may be issued by the Agency if a person can

demonstrate that:

(1) The structure was originally designed with a solid fuel burning device as the source of heat;

or

(2) The existing heat source, fueled with other than solid fuel, will not provide adequate heat.

EPA Analysis -- ORCAA Rule 8.1.5 does not appear to have a directly corresponding

provision in the existing SIP. However, ORCAA Rule 8.1.5 does add additional clarity and

procedures for determining how to apply the "Adequate source of heat" exemption already

contained in the existing SIP. The additional clarity of the ORCAA provisions strengthens

the SIP.

ORCAA Rule 8.1.6 Penalties

A person in violation of this Rule 8.1 may be subject to the provisions of Rule 2.5.

Existing SIP -- WAC 173-433-200 REGULATORY ACTIONS AND PENALTIES

A person in violation of this chapter may be subject to the provisions of WAC 173-400-230

• Regulatory actions and WAC 173-400-240 Criminal penalties.

EPA Analysis - ORCAA Rule 2.5 Regulatory Actions and Penalties contains civil and

criminal enforcement provisions consistent with the SIP approved provisions of WAC 173-

400-230 and 173-400-240.

12
OR CAA Rule 8.1.7 Sale and Installation of Uncertified Woodstoves

It shall be unlawful to install, sell, offer for sale, advertise for sale, or otherwise transfer an

uncertified solid fuel burning device unless the device has been rendered permanently inoperable

as a combustion device.

ORCAA Rule 8.1.8 Disposal of Uncertified Woodstoves

At such time as an uncertified solid fuel burning device is to be permanently removed from its

location it shall be rendered inoperable as a solid fuel burning device. A removed uncertified

solid fuel burning device shall not be sold, bartered, traded, or given away for a purpose other

than recycling of the materials to form something other than an uncertified solid fuel burning

device.

EPA Analysis - Both ORCAA Rule 8.1.7 and 8.1.8 provide clarity and procedures for

implementing the wood stove sale provisions contained in WAC 173-433 . 100(1 ) of the

existing SIP.

13
Attachment B - A Review of Changes to Chapter 173-433 WAC SOLID FUEL BURNING

DEVICE STANDARDS

173-433-030 Definitions

The definitions of terms contained in chapter 173-400 WAC are incorporated by reference.

Unless a different meaning is clearly required by context, the following words and phrases as

used in this chapter, shall have the following meanings:

(1) "Adequate source of heat" means the ability to maintain seventy degrees Fahrenheit at a

point three feet above the floor in all normally inhabited areas of a dwelling.

(2) "Certified" means that a woodstove meets emission performance standards when tested by an

accredited independent laboratory bete according to _-D- Q procedures er apccifled ,

the EPA in "40 60 SubpartAf Standar€is of Perf,grinari' cfor ;sid . tial 'g od,

Haters" as amended thro tth lay 1, 1990,

(3) "Coal-only heater" means an enclosed, coal burning appliance capable of and intended for

residential space heating, domestic water heating, or indoor cooking, which has all of the

following characteristics:

(a) An opening for emptying ash which is located near the bottom or the side of the

appliance;

(b) A system which admits air primarily up and through the fuel bed;

(c) A grate or other similar device for shaking or disturbing the fuel bed or power driven

mechanical stoker; and

(d) The model is listed by a nationally recognized safety testing laboratory for use of

coal only, except for coal ignition purposes.

°}- lawns -a-p son othe 4hai a-1 .:..r , .. lli

eulid fuel-4 im ailers

04- 'I;) 1;. x ea a ()repel-de aAmen- f=-envirc na-attt l- ua ty.

(€i (4) "EPA" means United States Environmental Protection Agency.

(7.) `[unpaired-Air ( utility" alder -a condition :cd farc byet:e1 y° -r-a -authority ..:. whenever:

(a) :\leteoro-1x.71 'teal conditie

c rte rr : at with;

(44-Total 5a.tspeaded l^ rtieula-t at -an ambient le of one-htmdr. 1twoaty-$iaae

if i-efo any p trs-u red cat --t early-f-Int-h-o-taiatw:-r-a-g;;; or

14
--ia14ie l . -th< --is- - iero d- rl;:11- - -di m-et = -f- ea- -xtrt- tree

$v l ^ -ii ty 7 ro-groins e°--eu tei--r a+ed ^3t t t r o t:

average: ()r

- ='arb(a.n + ^r ^ i^ art tnwa rl i + :1 vc of igl - .fteefi f-eia-Rta.rr = a utmillion pate- i-r4v v°olurr -(--t.t) a ;hu=ed-oil-(r- ht-1+o . it

l

seta bli,Ala€ l-l r.. o l.., ....+ t aeautbefity-:

) `= -an fa e-t ',err-au an y-i Aye}rte-h e- : r4rt€ets-o ry-iftipt fs -a : c^iid t l ! n r i do vice or

parts. f

.. r a...solid ...:fuel .. b s..raing-d \iee

(9) (5) "New Woodstove" means a woodstove that has not been sold at retail, bargained,

exchanged, or given away for the first time by the manufacturer, the manufacturer's dealer or

agency, or a retailer, and has not been so used as to become what is commonly known as "second

hand" within the ordinary meaning of that term.

(6) "Nona('feetedpellet stove" means that a )ellet stove has an air-to-fuel ratio equal to or ieatet

N.0. D_ .tgp- st l s X14g..g.cdlt;d l t) rat ry as _;t c.Ncl -1c _ it _rla€t 1, 4. _l lc p t.:,cl.r:,

sp ifle lhr the F I "._it?. 

R :.._(gt) pp nc i&W EE IFTlft.)[) 2

41FASl C ^11^ .m C3C __ R TO l i.`l L RAT IS) AN) MIN lt _AC FN \BL.. p B tBN

RA'I LS FOILW0OD- IRLL APPLIANCES" as amended through July- 1, 199Q.

{ (7) "Retailer" means any person engaged in the sale of solid fuel burning devices directly to

the public. A contractor who sells dwellings with solid fuel burning devices installed or a mail

order outlet which sells solid fuel burning devices directly to the public is considered to be a

solid fuel burning device retailer.

4(3) "Seasoned wood" means wood of any species that has been sufficiently dried so as to

contain twenty percent or less moisture by weight.

(12) (9) "Solid fuel burning device" (same as solid fuel heating device) means a device that

burns wood, coal, or any other nongaseous or nonliquid fuels, and includes any device burning

any solid fuel except those prohibited by WAC 173-433-120. This also includes devices used for

aesthetic or space-heating purposes in a private residence or commercial establishment, which

has a heat input less than one million British thermal units per hour.

(1) (10) "Treated wood" means wood of any species that has been chemically impregnated,

painted, or similarly modified to prevent weathering; -trial deterioration. and damage-due 4o

in-seats,

- 44) (11) "Woodstove" (same as "wood heater") means an enclosed solid fuel burning device

capable of and intended for residential space heating and domestic water heating that meets a11-of

th b l1 o w i t aria

15
i----l -tl e-pu 4s s_u.g_.d Ater i ig ualit€€; ion-under t r :a lm ist ati ;^ l ul

Ch ipter 314h-Di Ne rr+-2-I --Weed - i-t= ati; wedNovember 1984: A-ra airtee

fuel-ratio in--the ,nai do -elin- t ;r-1ess- ur-i -the- b of-ninety i - nt

-tne -ot-t';e..fu l-a gss-eensurn d in-the -low firing-cycle. The-la iiring ,yele means

1 ss tla^ a c>r e a;x ' $o -twenty-ti &-percent...of th : maxi-mum-Wm r ate eei Rved\4l -t ae

leer ,e e-eel or-the-minim .u.: --b+ rr - x 1 w he

(1 .)-For tl pue s-es- o-f- l teer-ni air g, uc li-ti :ati to un i€:r the lb h)ving criteria eont.ained

in °'40 CFR 60 Subpart AAA - Standards of Performance for Residential Wood Heaters

€late4-1Mary-2-6-.. 19 --`=a ..._amend d_1I1ts ugh_. il3y'_1 9():

(i) (a) An air-to-fuel ratio in the combustion chamber averaging less than 35.0, as

determined by EPA Reference Method 28A;

ii 0b) A useable firebox volume of less than twenty cubic feet;

CO A minimum burn rate less than 5kg/hr as determined by EPA Reference

Method 28;

(i A3 (.) A maximum weight of 800 kg, excluding fixtures and devices that are

normally sold separately, such as Clue pipe, chimney, and masonry components

not integral to the appliance.

Any combination of parts, typically consisting of but not limited to: Doors, legs, flue pipe

collars, brackets, bolts and other hardware, when manufactured for the purpose of being

assembled, with or without additional owner supplied parts, into a woodstove, is considered a

woodstove.

EPA Analysis - The redline strikeout version above shows changes to the state regulatory

provisions effective April 20, 1991. These changes strengthen the SIP by adding

Washington-specific certification standards and adding a dedicated WAC 173-433-140

Impaired Air Quality section.

WAC 173-433-100 Emission Performance Standards

(1) Woodstove sales. Canor before ;lanuary 1. 1 .995, a person shall not advertise to sell, offer to

sell, sell, bargain, exchange, or give away a new woodstove in Washington unless it has been

tested to determine its emission performance and heating efficiency and certified and labeled in

accordance with procedures and criteria specified

{ Requirements- foe ale-o l'ta -woodsLove; ia=- ashingtata...after- 4y_ 4,-.:i9

16
y--t-h-i-i 14I ---i+t u.-leGhapter 30., DiA 2-i -

Wok-N-1sto*e-Uertilk-t-fC'-da,ted-November 4-is-adf* y-ve-fecii-ee-a-i-rd-an

(li) By the-I:PA in "40 CFR 60 Subpart AAA - Standards of Performance for

Residential Wood Heaters" 4aeEl-Februirr) 24; 4 .9-8-8, is--depl-ed-b-i- geren-ee-d-nd

on file-al ct-,'-04al-Y as Lln'L.-TA.thipughiLIL1_9c ). AfterLo.lg JaL1995,

woodstove saleli shall eonip:%. with the requirements of subertion ofthis

section, Solid .t:ugt kumipg

soli -d--fuol bur-fting-4evies--in-Was-1--ton-a-fter ,, uly I.

I-90; a pFson shall-ut advtrtise to- oTfer t-sel sell bergaim-ekr1wige.-or gi*e

a way a ii e - ve ab-i tn- u ss it la as ber n leited (4 determie- its ern is.si

pr-feamenee-an.4 healing e-14'ii-en-c-y9 ee-rti lied and labeled-in acee-r4a-nee

pr-d-ee4ures i ": ythti--E-PA in "1-0 C FR40 i

I?&fim-m-an-r for- Roaic-ntil- Wo od-4-1 eat-rs" dat& I-i-e'truary 2-. -1-9 gg L id Is, _adopted-by

re-terenre, and-on 41e-at -ecology,

G-Y-Exrn mie:,s._..: It e -fo i se-lid fue Mg.{ vi-c-es-aFe efilptfrom-the-Teti uffiinents- f

this- sect towO--oh_d Cth.tl btlmi n eiees-sekl atrete-i-t-tA1-or-he-for-4t4y-4- 1 0 88.

0. y -scqid.- buFnill-g devic ...% kein ulldrr !rego - A-dmi n i sl ra ye- Ruls,

tea- l( 4 0. 21----Weudste-\-e-Cer-tif at' i t algid --ovrnbe-1-9-8.-be-afint he

apprpriate4 bli-nt-o-F writ -n proo ef-e-tiempt-;; :,,Lt.-s

(0- -A ny-solid--fiae-l-bii-mi-ng-de.ii4et -e-x-e--mptedndreed-4-aters" as amended titmuOlidly'., 88 -se- on

+i.He--Y;-(ze), (I(- 94,e-r-Ei), ale-:kMln

eempt-stat-as-fufnish-ed4ty-tle-EPA,

0-General ceftificat-in-ccdures, -sel-i',1-47uc4 brn-g-&a t hat is exe,mt-nd-tlet-efor--aet

ecrti-fielf ion undo Fe-1ft ,ay-be tested te-d en-ietemisi-n -perfoanti' lee i n-acc- Malice wi th-e it- ri a -nd procedures -ne - ess-Ari ge nt than Those

iinpui4rd track:T-5 4-CFR-6-Sub-pa* AA A- St rand -E if- P-e*4i Finanee f--- Resk4-ent I_Wod

-A 9 88. sub t--to-4 )e oll() willg-eefkliti-ons:

f a )--A II - criter ia and proreduyes ,.ihal beseal mitted44ytile-up for -e le* -and

appro.val- by erulogy rim: to. criiticatiun-tFiting;

tbt Cot-till-eat ion ol Cud-4umin, i det-4og ,; upon

apprii,\ r1-'o f te-4 reiiults that demo ns Irate -that . tEi -so-lad- furl b un ing- e" i3 ets-em is --ii

pep tern hit 'fee -slant tar-4 eq *- al-en 4o t se nrki er- " 40 R Subpart-A A-A -- t a n &al p;

e-f Pedb an c r---Re i 4ia-l--W t* 14e at ovs-'-Las-ain-ei Hied- -ti-iFet,44-i--d-*--l-7-4-0 8 ,

17
(-c t lie-atieit-jai=- - eo4st o-ve...4+AI-b -v: t fem= only .t1 e--see i f-:-ii$i ;: ig

plats-and specifications that r inally s i- -i t d ec--a- d apt ' t for

ti1"aEticaa-

)- ate- wid -em ss on: erlbr . :€ -sfiandard&- A n auth ority shall ... nut-adopt ..£ re i : . issi o

p e i"e- -a;aa ct-s -for solid :fu -- -:4. + v . _; t-ate;--m e t-ri ei x an , r . , c

sta:ktrE.L

{: FS r t °i ta-s ec -st-a ds-ior--eefti-l t-ion

fa)-: - =WOEdstcwe-aw l - or sa - a or sale, or re otJa ly-lv 148.8,aari g... a -D-E 7... e t:i icatio -label--s as l l

4

_ . -th -; t nd a ds- {ii-}

artip:alate- matter...under Sect io -340-21 _ 1-i-5 -' ,Ove;on Adis-tiMst--day:-i e-Rules- `1 € t(i, °

1l isi:€: 2l Wnc . .ey - : [ ' d r -°

i -- - -woo sty - .... E1 rt s ti-4 >r-sale,- f red - : - •l 3r-sold-in- -Washington-after

Jul-y- 4 , 4-98%i- bean' ng-an.- BP A eeft i fie-ation- lab-6 -sh cod. - the-4a nd-aftla--A)r

Sartie a- ter under `40 CF .- W k -- t a a44rfo °i- aafa . Eaf

Reside tia i- '• : f

€1.... eate :.se.°.-as-a e E1-Ki-tl o-ugh ul ,...l..a...1.

t .aalr d-ing r•eq a ntit, e

ca) E odst s-a=c g i-red-t€ be-labeled- prsuant-t osubset.:t°tE;r- {..1. j l... of is--s io shall

have lab elia--,ream-red. b _tl -1:..1 ia-•' Oregon - :dminis r tiv ulesa ` apt a3 - •;

i- aa. irv-WeeteNr -( ea4t`eati €1 : is NeY, n r 19847

1 .)... od tove -cap ^ 1 a$al f a l.. a:-ruin gde-vices- requir d-to-be-labs-iecl...pufs ant..:t

s: do - }(-aX -f -(-b)--Ea f

..ti s-se °ti n-shalt i. iw -l i-Ragg-require - ythe-EPA- Gash

bpart AAA S;ta : p 'dea-aiai za

Fl)..1:.;Eal i-alterat €^rc: r a raa Ea t a^° - , cl l a_..r ;taai a shall-ra t... It -4)4her theperm ile t a -a.

:a e t^ a t rrati€aa^: as ^a € t a' -deal(-Tr;-Ea • etrai•lea-shall rit)-t-ream e-o fender

inoperable any devices. or- 7ra• ponent:s--€f- a ay systems- installed by the ma of ac user .of

woedstevefor the purpose of controllco as ai t , othe4h • eplacara cz

r.l }.Ah-or-a atrv testin roc l Yer-. 1 ...

' s i :gt n-stYate- a af- ufa t€area- . ho--believes hissolid fuel

ba€r°aai_n ,: device; fort. rea- -; c+ Ala 3--1 -~t i. - n-a4itiefii-ati e tc ; as-pro i c that4h-et-FT -a a-a apply to cam:r( efn aria - iified procedure. ee egg

ixill-evaluate sueh-a.ppb anions, Ifdisaai pr- edi: he-sE-ati-d-fue-bb rni - -oYiee sltaall o Baia

s-ubj .:t t ›-the- 3A t ostin -rata oln -If-the app ktalc n- -is-ttppro-ved-i shall

an-a-Ileat: v e or a rc?-h4i d testing- eeed e. If-the proced-twe

e tyre;-res- sibi•I•ity- ". ; aaa €a:tI3r- •-to submit the-d-ek-lee-t-o-an-accredited testing

18
Ta-b }riatE.},i i nd...f : mi-sh-tiro o.c,M.t -\N-it -i ri -test -r; pt} est e s4 ll-!; i z s 4 4, aleflt ..to these

r 1 i- d - 1=•1', to s^i .^^ 1 t t icati€ on -y-1 is €1- It fi i ^ .o i- at a.-1=€- r-n

ai4•o-d--fnet- to c geed--s' t - li*-n-,-may 13' i led-by-ecology t** - evert-he-t :sti-n , period. 1:1-kt;-ri+ri

eert3` = 3Eir$tiE:7...may -b -Fene w€'£.1:

tc. .gy..: 99 a .la silg11 1191.20 s. 1-. 01:I t, set),

^i ra., Gara c l^axa ?r i eaway k tc toi 1 ^I71t t a l< e u1^ ;^ tmz ets tl ^ '090 t'«itc'cl tat

E ironmemal Protca;tion ;encv standardsforwoodstoves or ecluiv.alent standard thatmaylie

established ley flat stale-.,bu kilna cod council bt,, rude, Stll scclion (1 ). . 31 th s-dint shill not

1, l taa [ r€ l^l lc- iii000g.fP tc 1 Milt.. at:pl l ^ tie _ ztct 131,ll)nK ...

iltcl^lac s

j1 Sol_id . I ae.f burning devices.2 ter January 1, 1995 aperson shall naot advertise tosell. offer to

1,.-. ,c l r_I z g .mex s.,In e a}r rra i^ sad =t sollcl_f€ac i bur 3ie^ do r tit , in 'asl^rra=^tota raral xss iT 1a lti

^^^.e^r c^.rtikia^d ita.a.;.l li^b^la,a zir ^a^,c.^^tal^tlr^,,^^^tla 7r_^^^cllll,c:^; Glrtal crit^,a^iGa ^ ^^.c^. l8a_tcl..ia-a

Subpart AAA,ry _St,andards o Performance for Residential Wood Ficatfrs" as amended throtit,th

July 1, i 990, and meets the tollowinc particulate air contaminant emission standards andthc test

111AI:odolo c oi._:tla+ [ sited tat _ _ r r ttin tat ^rotecta^azt....

ra t_ , aaa 1 : c^ ;t . 4ii:nu ar ...1,

raat^.a^ ^i^^tc:s 1 a^^31 air ^tz^ . cr^^talr^.lc.,alt .^tiararl^tcl a.arade^r ^^ta^._t1.st r,letha^clol^=^^ ^ictoE^tc-cl. b^ t11^,

Ei7virorarnental Protection A 'tencv subset anent to such date:

1r4.a No atacl.- $lao ll all 0 Tarns per hour lttr- a it:_ r^ oodstoves: and

-._l2LEour irris1 one-half zr°n1iss_per° flour for iall other solid fuel bnfninu

{c. For..put.poses o this stibs ,t ton quin.al,tit" sh l_ near din emissions k it<..sp ihedin

111 is - saal e°ction_inurl)iplt d. h a statisticall' r laa ^l^ can'casion facto rdeteim cd byss:p co g „ tl at

relates the emission test results from the methodology established by the United States

I"tl.rirt tlt lctEt^j1_. f tRvl kc ti >la r g rt .-pl or IQ _11. _ 5,i ?1_ tc gilts tc t a_cs It A). tiN

a a ).gy sa tll^c^lucxlt cl Ist c - l^ tl t ,agg1r,,

EPA Analysis - These state regulatory changes effective April 20, 1991 and March 6, 1993

strengthen the SIP by adding Washington-specific certification standards. These standards

are among the most stringent in the United States.

WAC 173-433-110 Opacity Standards

(1) Phase-1- opacitI nvel :..p use a"k s all-not cause )} ...i. ll£D ...ni 3i at n of pi tntit fro,.

as- l-id fuel buarrr.i device Lerage o --l- iii-y- e-rt?e-ii! opacity for si-itnertna-i-ve

r inu-tei: i ^; a ar .ica l

{- -y.-1'h-a:s -.'. apzaeix -1 ea. . 1 e€° . ial 1: l a 9g ; A person shall not cause or allow emission of a

smoke plume form any solid fuel burning device to exceed an average of twenty percent opacity

for six consecutive minutes in any one hour period.

19
{3 i (), State-wide opacity standard. An authority shall not adopt or enforce an opacity level for

solid fuel burning devices that is more stringent than the state-wide standard.

(4) (.3.) Test method and procedures. •E4 A M thou anc proged r sspec ci_17v tb _

(iO. Appepc x A reference method 9 - Visual Determination of the Opacity of Emissions

from Stationary Sources as amended through July 1, 1990, shall be used to determine compliance

with subsections (1) and- (24 of this section.

(4) Enforcement. Smoke visible from a chimney, flue or exhaust duct in excess of the

opacity standard shall constitute prima facie evidence of unlawful operation of an applicable

solid fuel burning device. This presumption may be refuted by demonstration that the smoke

was not caused by an applicable solid fuel burning device. The provisions of this requirement

shall:

(a) Be enforceable on a complaint basis.

(b) Not apply during the starting of a new fire for a period not to exceed twenty minutes

in any four-hour period.

(5)_. & c cni _t rz .T is zp. . K.rgt it r p_c .icl .1)12-,.i,1)fr)!in rtic ^ f 1 _ppgation c,t otc3 1 11.0

burn in devicesa suchhisbrochures,_dc n 12 tratio s. ai l uuj),Jic education proQ.rat s, shon c

inc iWde information t i t opacity leyl s of t ri_p,er .en or less are att i ^ l 1e th:rc? p

c,r cr ticot .

EPA Analysis - These regulatory changes effective April 20, 1991 and March 6, 1993 create

more stringent opacity standards than the provisions in the existing SIP..

VAC 173-433-120 Prohibited Fuel Types

A person shall not cause or allow any of the following materials to be burned in a solid fuel

burning device:

(1) Garbage;

(2) Treated wood;

(3) Pf.astic and plastic products;

(4) Rubber products;

(5) Animal carcasses;

20
(6) Asphaltic products;

(7) Waste petroleum products;

(8) Paints and chemicals; or

(9) Any substance whichilormail emits dense smoke o • phaplitlus odors other than

paper to start the fire, properly seasoned fuel wood, or coal with sulfur content less than

1.0% by weight burned in a coal-only heater, - aw1• ic-h-ne -g i fly-et ist i1 ;- n 1 ,.gay:

{3hnoofsMe-as,

EPA Analysis - This minor clarification in the regulatory language effective April 20, 1991

does not significantly affect the SIP.

WA C 173-433440 Impaired Air Qualitv Criteria,

Impaired air quality shall be deters tined b^ ecology or an authurit in accordance i:'ith the

o11o mne criteria:

tl) " First stage impaired air quality" mmthe hrsk sta=ae indicates the pre :e1 ce ot:

si .ljat_1ic.til jt ttt<ttt i tea . iaicrt tj5 &t tel.. >ta^a1l €...tit cli^iiia t r_(i' .

it li.rF b•o ,Y^^.- 

: iai ' it j#,_1 1

d9t Sg. ^11t€ ttG tT B€ rt^€^^ 11T7. 17 r g.q.bit

(h) Carbon monoxide at or above an ambient level of eight marts cif' contaminant per million

(2) Second stag: impaired air t ua ity' the second stage indicates the presence of particulate

matter ten microns and smaller its d ameter (13 1i0 aat or above an ambient level of one hundred

1i •c nicr2graints per ttbic tt3etctF.

--(3 } On orafter July 1. 1995, it an authority has <oeo2rgphica 1v. limited the use of so1hd_fuel

batnine.de\i i es as5p3_ei11i ci }'1 i \C 1 7 3-4 3-1 0(6)a a sin* sta<n of im aired air kat,litv

ill apnl ._ fit'i_thhL...mgtauhieAl, z c to c _i . tlic- _ ^ rhorit single st.a e }i` itP.R11i= A_A

c latil t t Jcatc.Tltc f

.:e., sag .Q.t

Partictjlate . natter to np i_ ions and smallerit,d.iai net r ([3 NI 0 at or e an ambient

1 c_ 11pp cty.-illy lc att -.p art ^ tne_4 i -¢'.::

b) Carbon monoxide at or above an ambient 1 ;vel_of eight parts of contaminant , rpm..

i°?)W c spr. alil^ i 1 i s-. a^ ..c1ii€dtt ^.iaat i.a.t.........

(a) I'at ticulate matter ten microns and taller in (tit later
ME] l1(M) .l-''OR. THE 1 P;1 11 1 OF PAR"1'l . l., l.- ATE MA l FF R. \.S PM , IN THE

ATMOSPHERE"as r nt:-ed, tiro ugIi,rrle°

1, 1990W shallbe arse _t> rzthur l- fercnuc;_anbi -t

'M ^i^lt1 car .=r.i^ e r1 ..- tocta....lror►r-..,.. r 1

_ - _

till Moretimely ihient 1' 1 ^ , r a asurenient r tlti t s_ltr c utilized to eyalu t it .

impai€-r ent if ac 1^Prt_ end approved by ecolo, ty. Any alternative metl od for c'.alrrati

qu lrty n pnrr1munt car the - p...ucposu: of ctir.l^rzllpgsolhd.- IW€ e] b .tr a _c r ^c _u u 1 do cal tl c

.In ckk1 rr7tr_ tcl a,zr. ar al d to ,t icX r e l rc 11e aacatlOc^ O ac.!51, c l l=li . to t a _rct cncc:

ietlrocl lay arvr th n aticalr-elationship \ jit k a correlation coy tticienL of no less, th 1r 0,i83:,

(b Carbon monoxide CO).must _ measured o a i cr 2 l c? r av erwe in accordance with

prs!ccclrtr 5 sprcttrec , ihq..PA in ''40 ( F R50 A P N C

--__RFF .RF v^CT Mu111OT)

FOR 1"l-i DETERMINATION OF CAR1BO.N MONOXIDE IN `TI 11^'1I [ERE (NONDlSPUr RSiV TNE1 _:?,' ED PHO1OM1: TRY)" as amended through July 1, 1990„

_ r Q ats2o_1.1sc d.1, rz:.i.gI. i' LQ tqr cvzal frtitzor cat ;^oa c 1 Srt t oa.p t 31Ka tP_ ps

filet burning device use rust. be sited in accor fiance with EPA sitir criteria in or near affected

residents l e'as,

-

f .r

EPA Analysis - This entire section was newly added to Chapter 173-433 WAC effective

April 20, 1991 and has not previously been incorporated into the SIP. Approval of this

section is the first step towards the goal of updating the WAC to include PM2.5 trigger levels.

WAC 173-433-150 Curtailment

4-yA- erg. it -a r : , .. ,

caul eat l-ish en-t-wit-rar--a :-o l eat cat

th aa-tile n•mint, of solid fuel- .sl all-not -Wm- sold-fu. l...-in-any -sol:id.. -fuel-bumi r•M- device:-

'lx r ^rv 1^ 1 are {ix t l -s o `.s hi l +

¢h-} - 'lr ne-v r....e. eel ey- r:-.. :r...au-thorny- h^3s c1 e lar el irnp i:rc l...air-€T alit y--lac- r=-t

g o mpni -when-14 s of id- ` fi g cl i.^ i i t 'ea

a._? 'l rtc € l...G ? ^? '_caa -

la.il ;al^tlX rr rte-..hA5 .dectuptitb.g fit v t.gz 0 r IT a rccl a r_cl ^ it 1 1r_ sa

gc.q. rap tIl a;l#.a a.pp ,xon is r idea (, or",d?(Tun rf sal 4 7^1+11IT7 11 k 1tt1 t g,t ti.i3g,taphi4-O

area with art idequrvate source of heat other-dir a_solid fuel burning;..Lkn, ice r till roc}t €_perpte any.

solid fuel bur•nine, device. unless the solid fuel burning device is one of the following.

11.3 la 1 1 t ester -R l t.._s.i vc.4. fi r

22
" .....

leaders

e Ap.g0stoyK meeting the "Orego_p I)spartmq1t of Erivirsgmentaitv 1 .11tLie

gyi.i.g.i

. ....

(isati ratted November 198 .

h?''3 (gimpair e!k4il qual y

f(2t a ge9graphical .. .)cT,o)I ..Njai is .s tab 1:rle- ri-( .J

? rat tica^i acre ar Tit aim adequate source of 1otIlE thaiut_f,;liA burnii-tt! devkchall not

operate any soljd fuel burning device.

(m .JigpD:ei:.ccolo gy ..as laced.411. .. zi.tc.y.0 »c_f(Argc4st. a

its. at resitIgncesE coillurrejal establishrItitjyi thinthaLm.glaplilcArea with ttlLtIics.m.

source of heat other than a solid fuel burning device shall not o perate any solid fuel burning

device

(4)Th followinkY matrix (tra ical1v illustrates the applicability of different e apesof solid

NO burnirigdpyiecs ....

arc (

Burn Condition impaired it Quality Episode

Type o r Dev ice

First

Stage

Second

Stage

Alert,

Warning

Forecast

or

Emer genev

Pellet Stove

(nonaffected) OK NO OK NO

L.PA Certified

Voodsto-ve 01',t. NO OK NO

DEQ Phase

Woods krve OK NO OK NO

EPA Exempted

life b' ice NO NO OK NO

All Other D\ ices NO NO OK NO

NOTES: "OK indicates that the device may be operated

"NC)" indicates that the device may not 'be operated

.. P.rAkE.:T11.1.y 1:

vec i fie geo rn h '}1' lass

toll rw tact rs shal? be considered in the exercise )l this limitation

23
_T gs9g. lb gt.i.g 1 ot_ 6 _ 11 . r

°ic.

L iJi li,sig. _ a,9 mxa _ t_lb... lds rcl „ pct c^ tb ? '° {).

60 Sub, art AAA Standards of Pe foz mince for ResidentWood heaters" as amended t ' ou at

July I, 1990, to no i aim ie t of optionalt,rphie taiir fpiuty` sty In ircis^,

_

_00 hc: pQp attic _&nsityo of.1 _app iq ...... .r .a

(iiil'l hepublic healtheffects of the use of solidfueldevices which do not meet the standards

qs t_..lo t 1...in @'A t) £ I i .._fs _ ubp.1trl At A -

Standa.1_ c^ g ioi t- p<tncc_Wfor_ i l z ti ^l _99c

.itc t" aieilclcd tbictigllzl 1. z l c) ) .

i( h followina solid fuel devices areexempted from this 1i_^; iti ti€>ri:

(ii) Woodstoves certified and labeled by the EPA under "40 CFR. 60 Sub a rtAAA

S9andards of'Pet°lonti uee fc Residential _.. Wood Heaters" as amended t iouglaJuly 1_... 1990; or

iNionaffectedpelletstoves,

& 7 alitb€)rtt.v shitll, iil,lo^ " ari L C tT' )tit'?1a, .`."t1 71 )'^ tUi O- MC 01 le CYcOlIS t4 Ito

reside_ _o tiic :et_ phical area ak c ec lii ^€ c cxi€?11_

-._._(^1. 3 X71 .1►,tc t lal^ (, 19.;.:I11°,.r ctri: rticriil .3.a cl.c 1at_ y^ ilpred ^t1r ^^1.1ity ip

ac°c;^st dat ^c ^s teak ca tt^ ri oi^ia€ilc€E tip AC 11 ? 3 gat c_€;gr p sic l ^ir€ ^i c1^:1_ine

uG c1 y subsection (5.l_ of this section, a. cys€)n in a restden o1 co m :rel l estabils mcn csi_itltin

that .>cco )ra hical area shall not oper ate any solid fuel 'burn:iru' device.,

}.(7_) A person responsible for a al applicable solid fuel burning device already in operation at

the time an episode is declared shall withhold new solid fuel for the duration of the episode. A

person responsible for a an p plicable solid fuel burning device thati.s_.iloi-eer4i l._.ual ,re ; . "

.17-3433400 already in operation at the time impaired air quality is declared shall withhold new

solid fuel fat the d-aratioi of the impaired air quality. __Srnolce-visil le-from a-chim ey, lue_or __ _

exhaust duct after three hours has elapsed from the declaration of the episode or impaired air

quality shall constitute prima facie evidence of unlawful operation of an applicable solid fuel

burning device. This presumption may be refuted by demonstration that the smoke was not

caused by a solid fuel burning device.

(s) 01 Ecology, authorities, health departments, fire departments, or local police forces having

jurisdiction in the area may enforce compliance with the above solid fuel burning device

curtailment rules after three hours has elapsed from the'declaration of the episode or impaired air

quality.

EPA Analysis --- These regulatory changes effective April 20, 1991 establish the two stage

burn ban program currently in effect today. Incorporation of these provisions will

significantly improve the SIP.
3f--A--CSalesFee

¢-1-}== 1 r5o-a--s:- i ng a sold fuel-burning d viee dt etru i 1...impo e up 7udam:-- u)er• a

pu r ant- to--PLC W. 70.9448-.2, ,

t-2+ h --fee l a1-

(a)... et-at...a min i unt-e I ... €otta-r un ti1...Januar }--i9S-9.7 -and- a n llrv-thee afte it to € be

adj List d- upward....aecor ling to -i c:areas ;-in die, o s rn r...price,....inde

. ( b -) t i c -soli rb rniug 4es with tl - pti:^ t'l^€ t•.•i. ^

f .' --Ge1•k ed by -d- p-artm --th-retailsalestax a ndeF

(3) ff4he setter slieu-1 ai! h f :-l-yeR=.i i.^ osed or ret -t- e- to th -e ar-u-ze n.t o

c :: p .; r l r€f t .. erlaail be per sona.1-1- h-a 1- 3 t t 4 to for

tlae....amount-of (-Iae -fee-with tlie:;sith ituent-actiens taken ....i_ .... eorda e aith-tl--the et)-14e()tion

pfoy•i u0n.1 .ofic-tr pt r ;...; ?. RCA*,

EPA Analysis -- The Department of Ecology requested that this outdated provision be

removed from the SIP. because it was not a control measure relied on for attainment. I

reviewed the Thurston County attainment plan approved by EPA in 1993 and concur with

Ecology's determination that these fees were not a control measure relied upon for attainment.

25

Attachment C -- the following sample proposed Federal Register notice is intended to identify

key issues in review of Ecology's working draft. Upon receipt of a final SIP revision, the EPA

will review any changes to the SIP submittal as a result of local and state public comment

processes or any relevant EPA policy changes to adapt this sample proposed Federal Register

notice as appropriate.

6560-50-P

ENVIRONMENTAL PROTECTION AGENCY

40 CFR Parts 52 and 81

[Docket 4: EPA-RIO-OAR-2013.0088; FRL - ]

Approval and Promulgation of Implementation Plans; Washington: Thurston County Second

10-Year PM 13 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 of Washington on X.X. .X., for the Thurston County maintenance area (Thurston County)

for particulate matter with an aerodynamic diameter less than or equal to a nominal 10

micrometers (PM 10). The EPA is also proposing to approve both local and state regulatory

updates related to this maintenance plan.

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-RI 0-OAR-2013-0088,

by any of the following methods:

1
A. www.regulations.gov: Follow the on-line instructions for submitting comments,

B. Mail: Jeff Hunt, EPA Region 10, Office of Air,. Waste and Toxics (AWT-107), 1200

Sixth Avenue, Suite 900, Seattle WA, 98101

C. E-mail: RI 0-Public Comments(e epa.t ov

D. Hand Delivery: EPA Region 10 Mailroom, Stn Floor, 1200 Sixth Avenue, Suite 900,

Seattle WA, 98101. Attention: Jeff Hunt, Office of Air, Waste and Toxics, AWT -

107. Such deliveries are only accepted during normal hours of operation, and special

arrangements should be made for deliveries of boxed information

Instructions: Direct your comments to Docket ID No. EPA-R10-OAR-2013-0088. 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 lTryg:gg l .tipns_gc.v, including any personal information

provided, unless the comment includes information claimed to be Confidential Business

Information (CBI) or other information the disclosure of which is restricted by statute. Do not

submit information that you consider to be CBI or otherwise protected through

wv'rw•.rc,.gzilglions,.gov or e-mail. The www,rc tl_tzo__ s_,gpv 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 of your comment. If you send an e-mail comment directly to the EPA

without going through www.reg>u:latioiss.gov your e-mail address will be automatically captured

and included as part of the comment that is placed in the public docket and made available on the

Internet. If you submit an electronic comment, the EPA recommends that you include your

name and other contact information in the body of your comment and with any disk or CD-ROM

you submit. If the EPA cannot read your comment due to technical difficulties and cannot

2
contact you for clarification, the EPA may not be able to consider your comment. Electronic

files should avoid the use of special characters, any form of encryption, and be flee of any

defects or viruses.

Docket. 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

information the disclosure of which 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

r rvr,rer^ltxc>ns,c v or in hard copy during normal business hours at the Office of Air, Waste

and Toxics, EPA Region 10, 1200 Sixth Avenue, Seattle WA, 98101.

FOR FURTHER INFORMATION CONTACT: Jeff Hunt at (206) 553-0256,

hunt.jeff c@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 PM1 o Areas

A. Requirements for the Limited Maintenance Plan Option

B. Conformity under the Limited Maintenance Plan Option

3
V. Review of the State's Submittal

A. Has the State Demonstrated that Thurston County Qualifies for the Limited

Maintenance Plan Option?

B. Does the State Have an Approved Attainment Emissions Inventory?

C. Does the Limited Maintenance Plan Include an Assurance of Continued Operation of

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. Revisions to the Washington SIP

VII. Proposed Action

VIII. Statutory and Executive Order Reviews

I. This Action

The EPA is proposing to approve the limited maintenance plan submitted by the State of

Washington on XX.XX, for Thurston County, including approval of a monitoring system

modification for the area. The limited maintenance plan also includes Washington State

Department of Ecology (Ecology) regulatory changes that strengthen the control measures

contained in the State Implementation Plan (SIP) since our last approval on January 15, 1993 (58

FR 4578). In addition to the state regulatory changes, EPA is proposing to approve

corresponding local regulations adopted by the Olympic Region Clean Air Agency (ORCAA)

because they have direct implementation authority in Thurston County. Lastly, the EPA is

4
proposing to remove Chapter 173-433-170 Washington Administrative Code (WAC) Retail

Sales Fee from the SIP because this state provision was not a control measure relied on for

attainment or a required element of the SIP. The EPA has determined that removal of this

provision will not interfere with continued attainment and maintenance of the standard.

Similarly, the EPA is proposing to remove Chapter 173-433-200 WAC Regulatory Actions and

Penalties from the SIP incorporated by reference in 40 CFR 52,2470. The EPA reviews and

approves state submissions to ensure they provide adequate enforcement authority. However,

regulations describing agency enforcement authority are not incorporated into the SIP to avoid

potential conflict with the EPA's independent authorities. Likewise, the EPA has reviewed and

is proposing approval of ORCAA Rule 8.1.6 Penalties as having adequate enforcement

authority, but will not incorporate this section by reference into the SIP codified in 40 CFR

52.2470.

IL Background

The EPA identified a portion of Thurston County as a "Group I" area of concern due to

measured violations of the newly promulgated 24-hour PM 10 National Ambient Air Quality

Standard (NAAQS) on August 7, 1987 (52 FR 29383). Ecology and ORCAA worked with the

communities of Lacey, Olympia, and Tumwater to develop a plan for attainment of the PM1 o

NAAQS. The plan was focused on wood smoke reduction and was submitted in November

1988. On November 15, 1990, the Clean Air Act (CAA) Amendments under section

107(d)(4)(B), designated the Thurston County Group I area as nonattainment for PM to by

operation of law. The EPA published a Federal Register notice announcing all areas designated

nonattainment for PM10 on March 15, 1991 (56 FR 11101). In order to address the additional

5
moderate area requirements imposed by the 1990 CAA Amendments, Ecology submitted a

supplement to the attainment plan in November 1991. EPA took final action to approve the

entire plan on July 27, 1993 (58 FR 40056).

The control measures contained in the Thurston County plan rapidly brought the area into

attainment by 1991 and formed the foundation of the wood smoke reduction program still in use

today. As PMIO levels in the area steadily declined, the EPA redesignated the Thurston County

nonattainment area to a maintenance area on October 4, 2000 (65 FR 59128). In addition to

approving Ecology's redesignation request for the area, the EPA also approved a maintenance

plan to ensure continued compliance with the PM lo NAAQS for 10 years. The purpose of the

current limited maintenance plan is to fulfill the second 10-year planning requirement of Clean

Air Act section 175A (b) to ensure compliance through 2020.

III. Public and Stakeholder Involvement in Rulemaking Process

Section 110(a)(2) of the Clean Air Act requires that each SIP revision offer a reasonable

opportunity for notice and public hearing. This must occur prior to the revision being submitted

by a state to the EPA. The State of Washington provided notice and an opportunity for public

comment on the Thurston County limited maintenance plan from XXXX to XXXX. Under the

requirements of 40 CFR 51.102(a) the state also offered an opportunity for a public hearing .

XXXX . This SIP revision was submitted by the Governor's designee to the EPA on XXXX:.

The EPA evaluated the state's submittal and determined that the state met the requirements for

reasonable notice and public hearing under section 110(a)(2).

IV. The Limited Maintenance Plan Option for PM 10 Areas

A. Requirements for the Limited Maintenance Plan Option

6
On August 9, 2001, the EPA issued guidance on streamlined maintenance plan provisions

for certain moderate PKo nonattainment areas (Memo from Lydia Wegman, Director, Air

Quality Standards and Strategies Division, entitled "Limited Maintenance Plan Option for

Moderate PM i o 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 of probability, maintain the standard 10 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

of the 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 K° NAAQS.

Second, the most recent five years of air quality data at all monitors in the area, called the 24-

hour average design value, should be at or below 98 lLg/m3 . Third, the area should expect only

limited growth in on-road motor vehicle PMio 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 of continued operation of an 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

7
plan. Under either conformity rule, an acceptable method of demonstrating a Federal action

conforms to the applicable SIP is to demonstrate that expected emissions from the planned action

are consistent with the emissions budget for the area.

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 of the maintenance period because it is unreasonable to expect

that the qualifying areas would experience so much growth in that period that a violation of the

PKo NAAQS 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 CPR

93.158 (a)(5)(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 Thurston County Qualities 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 NAAQS. Thurston County has been

attaining the NAAQS since 1991 and the EPA formally redesignated the area from

nonattainment to maintenance effective December 4, 2000 (65 FR 59128).

Second, the average design value for the past five years of monitoring data must be at or
below the critical design value of 98 pg/m3 for the 24-hour PM I o NAAQS. The critical design

value is a margin of safety in which an area has a one in ten probability of exceeding the

NAAQS. Using the most recently available Federal Reference Method (FRM) monitoring data

for the years 2001-2005, the state's analysis demonstrates that Thurston County's average

design value was 60 ,ig/m3 , well below the 98 gg/m3 threshold. An FRM monitor is one that has

been approved by EPA under 40 CPR part 58 to measure compliance with the NAAQS. As

discussed later in this proposal, Ecology and ORCAA also calculated average design values

using more recent non-FRM nepheiometer data for the period 2008-2012. This more recent

monitoring data shows that PM 10 levels continued to decline with an average design value of 45

μg/m3 . The EPA reviewed the data provided by Ecology and ORCAA and finds that Thurston

County meets the design value criteria outlined in the limited maintenance plan option memo.

Third, the area must meet the motor vehicle regional emissions analysis test described in

attachment B of the limited maintenance plan option memo. Ecology submitted an analysis

showing that growth in on-road mobile PMIO emissions sources was minimal and would not

threaten the assumption of maintenance that underlies the limited maintenance plan policy.

Using the EPA's methodology, Ecology calculated a regional emissions analysis margin of

safety of 62 t1g/m3 , easily meeting the threshold of 98 gg/m3 . The EPA reviewed the

calculations in the state's limited maintenance plan submittal and concurs with this conclusion.

Lastly, the limited maintenance plan option memo requires all controls relied on to

demonstrate attainment remain in place for the area to qualify. The controls on wood smoke

reduction, Chapter 173-433 WAC Solid Fuel Burning Device Standards, were approved by the

EPA into the SIP on January 15, 1993 (58 FR 4578). As discussed later in this proposal,

9
Ecology made updates to Chapter 173-433 WAC strengthening the control measures since the

EPA's last approval. The EPA reviewed these changes and confirmed that the underlying

control measures remain in place, thus qualifying for the limited maintenance plan option.

As described above, Thurston County meets 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. If the state

determines that the limited maintenance plan criteria are not being met, it should take action to

reduce PM10 concentrations enough to requalify. One possible approach the state could take is to

implement contingency measures. Section V. I. provides a description of contingency provisions

submitted as part of the limited maintenance plan submittal. To insure this requirement is met,

Ecology 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 fiflventory?

Pursuant to the limited maintenance plan option memo, the state's approved attainment

plan should include an emissions inventory which can be used to demonstrate attainment of the

NAAQS. The inventory should represent emissions during the same five-year period associated

with air quality data used to determine whether the area meets the applicability requirements of

the limited maintenance plan option.

Ecology's Thurston County limited maintenance plan submittal includes an emissions

inventory based on Ecology's 2005 Triennial Emissions Inventory and the 2008 National

Emissions Inventory. These base years represent the most recent emissions inventory data

available and are consistent with the data used to determine applicability of the limited

10
maintenance plan option (i.e., having no violations of the PMi o NAAQS). The emissions

inventory focused on four significant source categories chosen based on a review of the original

maintenance plan. These source categories, in order of relative impact, are wood burning,

construction dust, road dust, and vehicle exhaust and tire wear. Since the Thurston County area

is primarily residential and governmental, other source categories, including industrial sources,

are insignificant. This data supports Ecology's conclusion that the control measures contained in

the original attainment plan will continue to protect and maintain the PM i0 NAAQS.

C. Does the Limited Maintenance Plan Include an Assurance of Continued

Operation of an Appropriate EPA-Approved Air Quality Monitoring Network, in

Accordance with 40 CFR Part 58?

PMip monitoring was established in the Thurston County area in 1985, with many

changes to the monitoring technology and requirements since. Beginning in 1990, Ecology and

ORCAA collocated a nephelometer with the existing PM i p FRM monitor. A nephelometer is an

instrument that is widely used to calculate particulate matter concentrations based on light scatter

measurements. While not an EPA-approved FRM monitoring method, Ecology and ORCAA

found that the nephelometer and the PM 1p FRM monitor were highly correlated. Because of this

high level of correlation between the monitors, as part of the 2007 animal network monitoring

report under 40 CFR part 58, Ecology requested replacing the FRM monitor with the

nephelometer so that resources could be redirected to more pressing environmental issues such

as ensuring that areas of concern in the state were in compliance with the recently revised fine

particulate matter (PM2.5 ) NAAQS, which is defined as particulate matter with an aerodynamic

diameter less than or equal to a nominal 2.5 micrometers. EPA approved this request on

11
November 16, 2007. A full description of the correlation data is included in the limited

maintenance plan submittal. The EPA is proposing to approve this monitoring system

modification, using nephelometer data to represent PM 1 p concentrations, under 40 CFR 58.14(c)

for the second 10-year maintenance plan period because this modification is a reproducible

approach to representing air quality in the Thurston County maintenance area, and the area

continues to meet all applicable Appendix D requirements evaluated as part of the annual

network approval process. As detailed in the limited maintenance plan, ORCAA will calculate

the PMI° design value estimate annually from nephelometer data through 2020 to confirm the

area continues to meet the PM1 o NAAQS. ORCAA also makes a commitment to continue

operation of a nephelometer in the Thurston County maintenance area through the 2020, the end

of the maintenance period, to determine PM 1 o levels. In the unlikely event that after exceptional

events are discounted, the second highest PM IO concentration in a calendar year based on

nephelometer monitoring exceeds the LMP threshold of 98 .ig/m3, Ecology, ORCAA, and EPA

will discuss reestablishment of FRM monitoring as part of the annual network monitoring

report process.

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 of any violation of the

NAAQS which may occur after redesignation of the area to attainment. The EPA is proposing

approval of ORCAA Rule 8.1.4(e) into the SIP. This regulation was passed in conjunction with

the 1997 maintenance plan submission and prohibits the use of uncertified woodstoves in the

.12
Thurston County maintenance area for the sole purpose of meeting Clean Air Act requirements

for contingency measures. The EPA reviewed ORCAA Rule 8.1.4(e) and determined that it

meets the contingency measure requirements. The contingency measure will be triggered if a

violation of the PM 1U standard occurs at the Thurston County maintenance area monitor based on

nephelometer and/or FRM monitoring. A violation of the PM 1U standard will be determined by

the procedures outlined in 40 CFR Part 50, Appendix K - Interpretation of the NAAQS for

Particulate Matter.

E. Has the State Met Conformity Requirements?

(1) Transportation Conformity

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 conformity

requirements of 40 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 of SIP 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

CFR 93.108;

(c) the MPO's interagency consultation procedures meet the applicable requirements of 40 CFR

93.105;

13
(d) conformity of transportation plans is determined no less frequently than every three years,

and conformity of plan amendments and transportation projects is demonstrated in accordance

with the timing requirements specified in 40 CFR 93.104;

(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 of the Thurston County limited maintenance plan, the area is exempt from

performing a regional emissions analysis, but must meet project-level conformity analyses as

well as the transportation conformity criteria mentioned above,

(2) General Conformity

For Federal actions required to address the specific requirements of the general

conformity rule, one set of requirements applies particularly to ensuring that emissions from the

action will not cause or contribute to new violations of the NAAQS, exacerbate current

violations, or delay timely attainment. One way that this requirement can be met is to

demonstrate that "the total of direct and indirect emissions from the action (or portion thereof) is

determined and documented by the state agency primarily responsible for the applicable SIP to

result in a level of emissions which, together with all other emissions in the nonattainment area,

would not exceed the emissions budgets specified in the applicable SIP" (40 CFR

93.15 8 (a)(5)(i)(A)).

14
The decision about whether to include specific allocations of allowable emissions

increases to sources is one made by the state air quality agencies. These emissions budgets are

different than those used in transportation conformity. 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 of general

conformity.

VI. Revisions to the Washington SIP

As previously discussed, the EPA approved the wood smoke control measures contained

in Chapter 173-433 WAC Solid Fuel Burning Device Standards on January 15, 1993, based on

state regulatory provisions in effect as of October 18, 1990 (58 FR 4578). Ecology subsequently

revised Chapter 173-433 WAC to strengthen the control measures with changes such as adding

one of the nation's most stringent state woodstove certification standards and by moving towards

a two-stage burn ban system to encourage adoption of the cleaner burning woodstoves. These

changes to Chapter 173-433 WAC were effective on April 20, 1991 and March 6, 1993, but were

not adopted into the SIP. A redline strikeout copy of the regulatory changes along with the

EPA's analysis is included in the docket for this action. Based on our review, the EPA is

proposing to approve Ecology's submitted 1991 and 1993 regulatory updates. In addition,

Ecology requested that the EPA remove from the approved SIP Chapter 173-433-170 WAC

Retail Sales Fee (state effective January 3, 1989) because this provision is not a control measure

or a required element of the SIP. After reviewing the original Thurston County attainment plan,

the EPA agrees that this provision was not a control measure relied upon for attainment and

15
removal of Chapter 173-433-170 from the SIP will not interfere with continued attainment or

maintenance of the NAAQS. Similarly, the EPA erred in including Chapter 173-433-200 WAC

Regulatory Actions and Penalties in the SIP incorporated by reference in 40 CFR 52.2470. The

EPA reviews and approves state submissions to ensure they provide adequate enforcement

authority. However, regulations describing agency enforcement authority are not incorporated

into the SIP to avoid potential conflict with the EPA's independent authorities. Therefore, we

will remove Chapter 173-433-200 WAC from 40 CFR 52.2470.

While the provisions of Chapter 173-433 WAC Solid Fuel Burning Device Standards

apply statewide per Chapter 173-433-020 WAC, Ecology requested EPA approval of ORCAA

Rule 8.1 Wood Heating and sections of ORCAA Rule 6.2 Outdoor Burning because ORCAA has

direct implementation authority in Thurston County. The EPA reviewed these regulations to

ensure they are as stringent as the existing control measures, with a full copy of the EPA's

analysis included in the docket for this action. It is important to note that the ORCAA control

measures, particularly burn ban trigger levels, focus on the more stringent and environmentally

relevant 24-hour PM2.5 NAAQS. Ecology and ORCAA provided an analysis of PM to and PM2.5

data collected by collocated FRM monitors at the Thurston County monitoring site. ORCAA

found that the two pollutants were correlated and one could be determined from the other with a

high degree of accuracy within the range of observations. The 24-hour PM 2.5 NAAQS revised in

2006 has a protection level 'of 35 μg/in3 compared to the 1987 PM1 o 24-hour NAAQS of 150

iglm3 . Based on the monitoring data from Thurston County, ORCAA found that in the winter,

the majority of PM I o is PM2 , 5. The statistical relationship between the two PM parameters

indicates PM2,5 1evels would need to exceed 139 1,tglm3 before the PMw D NAAQS is exceeded.

16
The EPA concurs that Thurston County would violate the 24-hour PM 2,5 NAAQS well before it

exceeded the PM 1 o NAAQS; therefore by setting burn ban trigger levels to protect the 35 μg/m 3

24-hour PM2.5 NAAQS, ORCAA is simultaneously protecting the 150 μg/r 3 24-hour PM I(

NAAQS. Finally, ORCAA Rule 8.1.4(e) provides a local clean air agency rule for implementing

the contingency measure which would prohibit the use of uncertified wood stoves. The EPA

reviewed the ORCAA regulations and determined that they strengthen the SIP and meet the

CAA requirements. As discussed above with respect to enforcement authorities, the EPA

reviewed and proposes approval of ORCAA Rule 8.1,6 Penalties but will not incorporate this

provision by reference in 40 CPR 52.2470.

TABLE 1 - SUBMITTED RULES

Agency Citation Title

State or

Local

Effective

Date

Submitted

Ecology 173-433-030 Definitions 04/20/91 XXXX

Ecology 173-433-100 Emission performance standards 03/06/93 XXXX

Ecology 173-433-110 Opacity standards 03/06/93 XXXX

Ecology 173-433-120 Prohibited fuel types 04/20/91 XXXX

Ecology 173-433-140 Impaired air quality criteria 04/20/91 XXXX

Ecology 173-433-150 Curtailment 04/20/91 XXXX

ORCAA 6.2.3 No residential or land clearing burning 02/04/12 XXXX

ORCAA 6.2.6 Curtailment 03/18/11 XXXX

ORCAA 6.2.7 Recreational Burning 03/18/11 XXXX

ORCAA 8.1.1 Definitions 05/22/10 XXXX

ORCAA 8.1.2 (b) and (c) General emission standards 05/22/10 XXXX

ORCAA 8.1.3 Prohibited fuel types 05/22/10 XXXX

ORCAA 8.1.4 Curtailment 05/22/10 XXXX

ORCAA 8.1.5 Exceptions 05/22/10 XXXX

ORCAA 8.1.6 Penalties 05/22/10 XXXX.

ORCAA 8.1.7 Sale and installation of uncertified

woodstoves 05/22/10 XXXX

ORCAA 8.1.8 Disposal of uncertified woodstoves 05/22/10 XXXX

17
VII. Proposed Action

The EPA is proposing to approve the second 10-year limited maintenance plan for

Thurston County submitted by Washington State. The state's submittal also included a request

to approve state regulatory updates to the original control measures included in Chapter 173-433

WAC as well as corresponding local ORCAA regulations, The EPA is proposing to approve

these regulatory changes as well as corrections to the EPA's January 1993 approval because

these changes strengthen the SIP.

VIII. Statutory and Executive Order Reviews

Under the Clean Air Act, the Administrator is required to approve a SIP submission that

complies with the provisions of the Act and applicable Federal regulations. 42 U.S.C. 7410(k);

40 CFR 52.02(a). Thus, in reviewing SIP submissions, the EPA's role is to approve state

choices, provided that they meet the criteria of the 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 of Management

and Budget under Executive Order 12866 (58 FR 51735, October 4, 1993);

• does not impose an information collection burden under the provisions of the Paperwork__

Reduction Act (44 U.S.C. 3501 et seq.);

• is certified as not having a significant economic impact on a substantial number of small

entities under the Regulatory Flexibility Act (5 U.S.C. 601 et seq.);

18
• 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, April 23, 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) of the National Technology Transfer

and Advancement Act of 1995 (15 U.S.C. 272 note) because application of those

requirements would be inconsistent with the Clean Air Act; and

• 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, 20.00), because the SIP is not approved to apply in Indian

country located in the state, except non-trust lands under the terms of the 1989 Puyallup Tribe of

Indians Settlement Act. The EPA notes that this action will not impose substantial direct costs

on tribal governments or preempt tribal law.

List of Subjects in 40 CFR Part 52

Environmental protection, Air pollution control, Particulate matter, and Reporting and

19
recordkeeping requirements.

List of Subjects in 40 C!R Part 81

Environmental protection, Air pollution control, National parks, Wilderness areas.

Authority: 42 U.S.C. 7401 et seq.

Dated:

Regional Administrator

Region 10..

20
SIP Revision

for the

Thurston County, "Washington

Second 10-Year Limited Maintenance Plan for

PM1o

February 2013 PUBLIC REVIEW DRAFT

Publication no. [xx-xx-xxx]
Publication and Contact Information

This report is available on the Department of Ecology's website at

h_tll^s;/^fc^rkc'^^^^_wry.^^v^^t-^v:/^?.t^.E^lctatic^^sf 5u_^nG^^3 ►-t!^'^7^^s1xxxx:^x^,lrttxil

For more information contact:

Xxx cxxxx

Air Quality Program

P.O. Box 47600

Olympia, WA 98504-7600

Phone: (360) 407-6600

Washington State Department of Ecology - www.ecy.wa.gov_-

0 Headquarters, Olympia 360-407-600000.

a Northwest Regional Office, Bellevue 425-649-7000

0 Southwest Regional Office, Olympia - 360-407-6300

0 Central Regional Office, Yakima 509-575-2490

0 Eastern Regional Office, Spokane 509-329-3400

If you need this document in a format for the visually impaired, call the Air Quality Program at (360)

407-6600. Persons with hearing loss can call 711 for Washington Relay Service. Persons with a speech

disability can call 877-833-6341.

ii
SIP Revision

for the

Thurston County, Washington

Second 10-Year Limited Maintenance Plan for

PMzo

Air Quality Program

Washington State Department of Ecology

Olympia, Washington

Project Lead: Laurie Hulse-A/foyer, Air Quality Planner

In conjunction with

Olympic Region Clean Air Agency

iii
Table of Contents

List arFigures and Tables '

Tables -'---'- ---»

Figures ' ' '-'--- '

Acronyms and -

_ vi

Abstract/Executive Summary --

Introduction

Background _ 2

Limited Maintenance Plan nnou -- -- 4

Particulate mMatter ^x:w*^wwo~x .- _ .-- ^_^-- '- 6

smmwn Inventory -----' '--'-- 12

Control I

Contingency Measures 15

Commitment to Continued Monitoring w; /v

Verification of Continued ^oainmm* 'm

Summary of Maintenance Plan Commitments I

Required Plans Complete _--_----' ....... ....... ........................ n

Appendix A. Limited Maintenance Plan Qualification '- . -'--^-' ' '-_m

Appendix B. Ecology 20oNetwork Report/EPA approval -' o

Appendix c. Ecology rvovm*^u pmmmwupliomm,m---._ ^^

-- z

'o/

Appendix D. ORCAA Collocated Monitoring 'r

. ^ cn

Appendix E. Emission Inventory Documentation so

Appendix F, Inventory Preparation Plan _-' ' ....... ........... ............... 34

Appendix G. Olympic Region Clean Air Agency Regulations -. 42

Appendix H. Washington State Regulation 40d Fuel Emig 46

iv
List of Figures and Tables

Page

Tables

Table 1. EPA Actions and Plan Submittals for Thurston County 4

Table 2. Particulate Mailer Monitoring at Lacey-College Street 7

Fable 3. TCMA Annual and Winter Day PM„ c Emissions 12

Table 4. Comm] Measures in ORCAA Rules ] 3

Table 5. Requested EPA Action on Chapter 173-433 WAC Solid Fuel Burning Devices 15

Table 6. Second 10-Year LMP Commitments 16

Figures

Figure I. TCMA and the Lacey-College Street Particulate Monitoring Site 3

Figure 2 Lacey-College Street Historical PM lc Concentrations S

Figure 3 Lacey-College Street Correlation : 9

Figure 4. Lacey College Street NPM 10 Values -- 2006-2012 10

v
I

Acronyms and Abbreviations

Average, Daily Vehiclc)4jles.my. .led

AEEZR n.lr_lrt?>_tsstons. .gpol#i-n.

. Rule

AP42 TPA'.. Compilatioli. of-Air Pollutantmissioci. Factors

AQ[ Atr.Qndty .lndex

A.QS Air ty 5ystcm

b,,, A measure otligl.t scatter,...tieringcooefticiet7t

CAA... ....................CleanAirAct

CAAA Clean- Air Act Amendmeits

CARB California-Air ResourcesBoard

D.QQ Data: Quality, Objecives

DV Design. Valve

Ecology Washington 5tate_Dei?artrnen ofEcology

EPA _ :S.Environ}netital ProtectionAgency

FEM Federal. Equiva!gilt ll!tethnd

FIR Federal-Refe once Metih

g/h bran?s_.er, liour

HPN[5 U_ HighwayPerformance- Monitoring_System

]PPIQAP -- fnvenlory Ptcpaiat1ol? Plan-std -Qtt^lity_AssuranGelan

LMP ------ Limited -Maintenance- Plan

MO. Margilt. ofSafety

NAA Nonattainment- area

NAAQS i`(ation. Anib ei?t Air_.iiality tada>As

NAMS_ , Nattc ltal An?.ient Moni.ot ft1. Sites

NEI EPA.. "J ittonal.Emissioi.lnventoiy

NPMg -_----_--.-..-._.. Partieul,i1 M:attei__ -1 mielons_o?- less fron?_lrepbelometervalues

NPM2 , ,---- Particultae Matter 2 5 .lnlcion' o1 less- imont nepltelometervalues

--- - ORCAA................

Olympic P c ion Clea n.A t rAgency

PM]o -- --- Partic}iiltc Eattct teg it»crons. or- esa

PMa :trail ttc. J[ietz 2.s turons of less

RAC Reaxonal?l^r_ <:.

.. ailhle-Cni?trol_Technologies

KW esidential Wsod Combustion

51P... . Mate - linplcment ttton. Plan

SLAM State_and. oval Ayn rent- . ......g.S....

TCMA Tluirst^n Catrrlty..Maintenane.e. Area

Thurston Regional PlannmgCoutacil

TEOM..... Tanel.ed l;lerneltt Olattng M..c.obalance

TSP Tot7l Sus}^ended Pa rticulate

glln^ micr.og^_ams-per cubic eter

VMT_ . _ „ Vehicle Miles-Traveled

WRAf Wstern Regional- Air_C'artnclsl?ip

WSDOT Washington State_Departtalm gf. Transt?otrtation

vi
Acknowledgements

The authors of this report would like to thank the following people for their contribution to this study:

Olympic Region Clean Air Agency:

• Robert Moody

• Jimmy Werner

• Odelle Hadley

Washington State Department of Ecoloy

• Laurie Hulse-Moyer

• Doug Schneider

• Sally Otterson

• Joan McMillen

• Mike Ragan

• Sean Lundblad

• Anya Caudill

• Melanie Pearson

• Melanie Forster

vii
Abstract/Executive Summary

The cities of Lacey, Olympia and Tumwater in Thurston County, Washington meet the federal standard

for Particulate Matter 10 microns and smaller (PM [0). This State Implementation Plan (SIP) revision

. explains how this area will continue to meet this standard) through 2020. EPA sets standards for particle -

pollution because smaller particles such as soot, dust, and unburned fuel can penetrate deeply into the

lungs and cause health problems. The current 24-hour federal health standard for PM 15, set in 1987, is 150

micrograms per cubic meter (p.g/m 3 ). To maintain compliance with the standard, monitored levels should

not exceed this level in the area more than once a year over three years.

The Lacey, Olympia, and Tumwater area, called the Thurston Cotinly < Maintenance Area (TCMA or

maintenance area), violated the 24-hour standard in the late 1980s. Smoke from woodstoves and

fireplaces caused the TCMA to violate the standard. Control measures brought the TCMA into attainment

by 1991. EPA redesignated the TCMA to attainment in 2000. The Olympic Region Clean Air Agency

(ORCAA) has enforcement authority for the TCMA.

The Clean Air Act (CAA) requires an area being redesignated to attainment have an EPA-approved

maintenance plan that provides for the area's continued compliance with the PM„ standard for 10 years.

A second 10-year plan must follow the first 10-year plan: This document, the SIP Revision for the

Thurston County, Washington, Second 10-year Limited Maintenance Plan for PM Rt.,

• meets the requirement for a second llThyear plan,

• covers the period through 2020, ancl

• fulfills the final maintenance planning.' requirements of the CAA for the TCMA.

This plan includes justification for using an alternate monitoring method. Different types of monitors and

methods have been used to assess particulate matter levels since 1985. ORCAA currently operates a

nephelometer to track air quality. While not a federal r^ei'erence method, both Ecology's and ORCAA's

research shows that for this area, the nephelometer produces results similar to the federal reference

method. Therefore, this monitor is a reasonable, accurate and reliable way to represent particulate matter

levels and demonstrate compliance with the I987 PMrq standard for the TCMA.

Since the maintenance area meets EPA criteria and shows little risk of reviolating the federal standard,

Ecology is submitting a streamlined maintenance plan called a Limited Maintenance Plan (LMP). The

LMP relies on the same control measures that brought the area into attainment and supported the initial

maintenance plan----basical ly,

• curtailment of wood burning devices during periods of impaired air quality

• certification of new wood burning devices

• rules governing sale and removal of uncertified wood stoves

• restrictions on outdoor burning

While these control measures have not changed, the underlying law and rules have. Ecology requests EPA

approve ORCAA and Ecology rules that reflect these updates.

ORCAA will continue to monitor air quality in the TCMA and document the area's continued compliance

with the 1987 PM i c standard.
Introduction

This State Implementation Plan (SIP) revision explains how the cities of Lacey, Olympia and Tumwater

in Thurston County, Washington currently meet and will continue to meet the 1987 National Ambient Air

Quality Standard (NAAQS) for particulate matter ten microns or smaller (PM,o) through 2020.

Washington State Department of Ecology (Ecology) prepared this plan with the Olympic Region Clean

Air Agency (ORCAA), the local clean air agency with jurisdiction over Thurston County.

Particulate Matter Standards - The Environmental Protection Agency (EPA) sets air quality standards

for particulate matter to protect public health. Particle matter pollution is a public health issue because

smaller particles can penetrate deep into the lungs and cause health problems. Particle matter comes from

soot, dust, and unburned fuel suspended in the air. EPA revised the particulate matter NAAQS from total

suspended particulate (TSP) to PM I0 on July 1, 1987, since smaller particles were determined to be more

harmful. The primary or health-based 24-hour standard for PM l0 was set at 150 gg/m3 , and cannot be

exceeded more than once a year on average over three years. This standard remains in effect today. Ten

years later on July 18, I997, EPA set a 24-hour standard for fine particulate matter (particulate matter 2.5

microns or smaller or PM2 5) at 65 pg/m3 . In 2006, the 24-hour standard was revised from 65 pg/m 3 to 35

μt/m3.

Thurston County Maintenance Area Compliance History - Thurston County violated the 24-hour PM to

NAAQS in the late 1980s in the winter and wood smoke was the cause. These violations were recorded at

ORCAA's PM I0 monitoring site on College Street in Lacey (Lacey-College Street). When the 1990

Clean Air Act Amendments (CAAA) were passed, EPA designated the Thurston County Maintenance

Area (TCMA)' a nonattainrnent area, an area out of compliance with the PM [0 standard,

Ecology and ORCAA prepared plans to fulfill Clean Air Act (CAA) requirements. An attainment plan

deael ibed how the area would comply with the standard; a maintenance plan described how the area

would stay in compliance.

Since woodstoves and fireplaces contributed the most to particulate matter levels in winter, limiting wood

burning when air quality was poor was oneofthe control measures included in the attainment plan. Air

quality improved once this and other measures ream the plan went into effect. The control and

contingency measures from the attainment and maintenance plans are still in place. By the early 1990s,

the monitors were consistently recording values below the standard. The area has met the standard for

well over two decades,

Plan Structure - This SIP revision includes the TCMA compliance history and describes how the area

met and will continue to meet the standard, as well as what will be done it the standard is exceeded. This

plan also includes other EPA-required elements, such as an emissions and monitoring review.

This document is organized as follows:

+ Section 2 -- TCMA and PM ,o Standard Background - describes the area's compliance history and

contains background information on the PM I0 standard

• Section 3 - Limited Maintenance Plan (LMP) Option - describes the criteria an area must meet to

At Mt. View Elementary School-SLAMS. Site ID 53-067-0013

Comprised of the cities of, Lacey. Olympia and Twowater. as well as unincorporated areas of Thurston County lying within or between the

municipal boundaries.

1
qualify for this option and how the TCMA meets these criteria

• Section 4 - PM 10 Monitoring History - provides a brief history of monitoring in the 7CMA, an

evaluation of the relationship of PMro to PM 2.5 in Thurston County and justification for using an

alterative monitoring method

• Section 5 - Emission inventory - includes historical information on the most significant PMro

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, the current rules that maintain and enforce these measures and includes a

request that EPA incorporate and include the updated rules in Washington State's SIP

• Section 7- Contingency Measures - describes the provisions that are in place in rules and will be

taken, if the PMro standard is violated

• Section 8 e- Commitment to Continued Monitoring -stat that continued monitoring will be

done

• Section 9 - Verification of Continued Attainment - describes how continued compliance will be

confirmed

• Section 10 - Summary of Maintenance Plan Commitments - outlines commitments of this plan

• Section l 1 - Completion of Required Plans - states that this document fulfills federal planning

requirements

Background

Historical information on the TCMA, its compliance, and federal plan history are below.

Thurston County .Mainfena ree Area - The TCMA is located in Washington State, west of the Cascade

Mountains and south of Puget Sound. The topography influences the meteorology at the site. The

monitoring site is located in Lacey, Washington, at an elevation of70 meters (230 feet). Figure l shows

the maintenance area boundary, the location of the three cities in the TCMA and the Lacey-College Street

monitoring site.

2
Figure 1. 1L lvlA and the Lacey-College Street Partieirtate Monitoring Site.

Thurston County Compliance History - The Lacey-College Street monitoring site recorded ten

exceedances of the PM 10 standard between 1985 and 1988. When the new PMI0 standard was set in July

1987, EPA identified Lacey, Olympia and Tumwater as a "Group I" area of concern, that is, at risk for

violating the 24-hour PM i o standard (52 FR 29383, August 7, 1987). The 1990 Clean Air Act

Amendments (CAAA) required EPA to designate Lacey, Olympia and Tumwater a moderate PM I0

nona.ttainment area because of violations of the PM IO standard. The area attained the standard by 1991,

was redesignated by EPA to a maintenance area in December 2000, and has remained in compliance with

this standard.

Plans Submitted - Ecology and ORCAA prepared plans to fulfill CAA requi rements. An attainment plan

described how the area would comply with the standard; a maintenance plan described how the area

would stay in compliance. These plans are:

• Attainment Plan comprised of two submittals- the original dated November 1988 and a

supplement dated November 1991

3
Redesignation Request and Maintenance Plan: dated June 1997'

The following table summarizes the EPA actions, Ecology and ORCAA submissions and EPA approvals

for this area.

Table I. EPA Actions and Plan Submittals for Thurston County

EPA Actions or Requirement Agency Response or Plan I-EPA Approval

Attainment Plan

New standard set for PM 10- July 1,

1987

Thurston County designated Group I

PM 10 area of concern - August 7,

1987

Thurston County designated PM [0

nonattainmcnt area by 1990 Clean

Air Act Amendments - November

15, 1991

I

Redesignation

State implementation Planfor

Thurston CountyParticulate Matter, A Plan for

Attaining and Maintaining the

NAAQSfbrPlvi0 , dated

November 1988, publication

no. 88-28 (Ecology, Comis,

Sue, et. al)

Supplement to above plan,

November 199is:(Ecoiogy,

Schneider, Doug, et.. al)

_ _ y

Request and ^Mauttenance Plan

Plan fulfilled EPA requirements

for Group I Areas

Supplement developed to

address the 1990 CAAA

EPA approved July 27, 1993

(58 FR 40056), effective

>eptember 2 7, 1993 _ J

amp

Redesignation request must be,

accompanied by a maintenance plan

(CAA I 75A (a))

Redesignation Request and

Maintenance Plan for

1.'htrr:5tora County, Washington

Ptlydao r^onattainrnenl Area,

June E, 1997, (ORCAA,

Systems Applications

International, 'Moody, Carr,

et, al)

1 EPA approved October 4, 2000

(65 FR 59128) and the TCMA

became a maintenance area

effective December 4, 2000.

This plan, the SIP Revision for the Thurston County, Washington Second 10-Year Limited Maintenance

Plan for PM t o, is the last maintenance plan for this area. This maintenance plan revision ensures

compliance through 2021) and fulfills the second 10-year planning requirement of CAA Section 175A (b).

Limited Maintenance Plan Option

Because the TCMA is a maintenance area, the CAA requires Ecology submit a plan that demonstrates

compliance with the NAAQS through 2020. EPA developed the Limited Maintenance Plan (LMP) option

so areas with little risk of reviolating the PM Lo standard could be easily redesignated from nonattainment

to attainment (also called maintenance status). EPA also allows states use this policy to prepare the

3 This plan was withdrawn after EPA established a revised PM ' , standard and instituted a process for revoking the old standard.

The plan was withdrawn over concerns that if the plan were approved, the area would have a maintenance plan and a 10-year

commitment for a standard that no longer existed. However, in 1999, the US Court of Appeals vacated the 1997 standard and

EPA determined that the 1987 standard still applied. As a result, ORCAA requested that Ecology resubmit the maintenance

plan to EPA.

4
required second 10-year maintenance plans if the area meets the qualification criteria in the EPA LMP

Option Guidance (LMP Guidance). This section describes the advantages of the LMP option and how the

TCMA meets the qualification criteria.

Maintenance Demonstration; A maintenance plan normally contains an emissions or modeling

demonstration that shows how the area will stay in compliance through the 10-year maintenance period.

This demonstration normally requires a projected emissions inventory. However, an area meeting the

LMP qualification criteria is at little risk of violating the standard because emissions are not expected to

grow sufficiently to threaten maintenance of the standard. Therefore, when an area meets the criteria, the

maintenance demonstration is presumed to be satisfied and there is no need to project emissions over the

maintenance period.

Transportation Conformity: The transportation conformity rule (40 CFR Parts 51 and 93) applies to

nonattainment and maintenance areas. It is not reasonable to expect that motor vehicle emissions would

grow enough to threaten maintenance, if an area expects only limited growth in traffic emissions and

qualifies for the LMP option. Therefore, a regional emissions analysis is not required to determine

whether the region's long-range transportation plan and short-term transportation improvement program

conform to the maintenance plan. Other conformity requirements, such as consultation between agencies

on air quality impacts of transportation projects, still apply.

LMP Qualification Criteria - To take advantage of the LMP option, an area must be attaining the

NAAQS, cannot exceed the average 24-hour PM1o design value of 98 vg!m3 and should expect only

limited growth in on-road motor vehicle emissions. The TCMA meets these criteria as described below;

supporting information can be found in Appendix A.

Flow the TCMA qualifies for the LMP option:

1. The area must be attaining the NAAQS: Thurston County attained the standard in 1991, was

formally redesignated to attainment in 2000, and has been in compliance with the PMV1 10

standard for well over two decades.

2. The average 24-hour PM!n desi wt value for the area based upon the most recerrs ive rears of

data should not exceed 98 pg/n . A design value is the statistic based on monitoring data that

determines an area's compliance status. tht: I 'at(? Qu4d pep cllre t lhS LI Q,raiL floc 11 _13a,e {

1111 the most recent lrt (t. E 1}ts of data The TCMA design value is based on Federal Reference

Method (FRM).24-hour PM. 1 o monitoring data from 2001 through 2005 the Lacey C€-liege

Ste Let-sitei 60 m'. Geitd so da-t;e-eh . rl inu snf-ark; e-l t,SC .c,n..t ,,o

eta€_t`'- t"he ma rrs sr entcatiors from 2001through 200i5fromt-RM-RM- 1 &nl+e r s A

pg t' Tl c: rfioyt_cceint cie i i yaluc estimigq 6ls....13_aa.1IJ aftiiy4 fnuthocl,, u ing?()t3S..tu

2012 values, is 45:2 pg/rn 3 , Since both these values are below 98 pg/m3 , the value stipulated in

the LMP Guidance, the TCMA meets this condition.

3. The area should expect only liuliled growth in on-road motor vehicle P kil n Emissions

(including fugitive dust) and should have passed a maim- vehicle regional emissions analysis

test, (i.e., passes the Motor Vehicle Regional Analysis Methodology found in Attachment B oJ'

the LMP Guidance.) TCMA meets both these criteria. First, the Thurston Regional Planning

.l weghnan, Lydia, Limited 5laimennnee Plan Option For Moderate PM,„ Nonnuainment Areas, EPA memo, August 9. 2001

D Ibid. pp 3.

5
Council (TRPC) projects only limited growth in on-road motor vehicle PM t o emissions for the

TCMA from 2010 through 20207 . Second, the area passes the motor vehicle regional

emissions analysis test,

As described above and in Appendix A, this area clearly attains the NAAQS, the design values are well

below the defined margin of safety and the growth in PM 10 emissions from motor vehicles will not

threaten compliance with the standard, 't'hus, the TCMA meets the LMP qualification criteria and

qualifies for the LMP option.

Ecology provided its analysis to EPA Region W. EPA Region 10 and Ecology mutually agreed to the

LMP approach, ORCAA will calculate the 5-year design value estimate and provide it to Ecology

annually. Ecology will include a statement that the area continues to qualify for the LMP option in the

annual monitoring network report.

Particulate Matter Monitoring

This section discusses the history of PM 10 and PM2.5 monitoring in the TC'MA, the analysis that

demonstrates using a correlated nephelometer is a reasonable way to estimate PM lo levels in Thurston

County, and the relationship between PMIo and PM2 .5 in the TCMA.

Particulate Matter Monitoring History--- ORCAA conducts ambient monitoring in Thurston County. The

Lacey-College Street site has long served as the monitoring site that represents particulate matter levels in

Thurston County.

Types of Particulate lonitors - At the Lacey-College Street monitoring site, PM r0 and PlM2 5 have been

measured using both Federal Reference Methods (FRM) and alternative methods not approved by EPA

fix' comparison to the NAAQS. The following monitors have been used to measure particulate matter at

the site.

e FRM

o Two different models ofPM,r, hall Volume (Hi-Vol) monitor,

o PM25 sequential monitor

e Alternative Methods

o PM25 Tapered Element Oscillating Microbalance (TEOM),

o Two types of nephelometers

Nephelometers have been used at Lacey-College Street and other locations in the maintenance area for

decades. A nephelometer measures light scatter (b, eat) and, when correlated with a FRM instrument,.

accurately represents particulate matter levels. Ecology and ORCAA analysis shows that the

nephelometer produces results similar to those recorded with the FRM PM i0 instrument at Lacey-College

Street. Particulate matter results derived from nephelometer values for PM t0 and PM2.5 are designated as

NPM 10 and NPM2,5 , respectively.

-Monitoring. Dates By Pollutant - From November 1985 through April 2006, PM 10 was measured by FRM

and the data reported to.EPA's Air Quality System (AQS), FRM PM2.5 monitoring began after adoption

of the federal fine particulate standard. ORCAA also ran a nephelometer to compare against FRMs for

7

Thurston Regional Planning Council. 2011 Update to the Thurston Regional Transportation PLm. Section 4. Air Qurdity Conrormity,

page 4, Table labeled, Maintenance rhea i'illTand meal P1.110 Mobile Emissions, June 3. 2011.

r,
both PMIO and PM 25 . Table 2 below presents monitoring by pollutant type, instrument, EPA approval

status and whether the data is in EPA's Air Quality System (AQS).

Table 2, Particulate Matter Monitoring at Lacey-College Street

Pollutant Monitoring Dates -Instrument

EPA Monitoring

Designation Status

(Reference, Equivalent,

Alternative Data in AQS?

PMIO l/1/1985 to 7/31/1988 HI -VOL SA321 FRM - Reference Yes

PM 10 8!1/1988 to 4/29/2006

HI -VOL

SA1200/CMW 2000 FRM - Reference Yes

PM2,5

10/31/1998 to

2/29/2004

R&P Partisol-Plus

2025 Sequential

monitor FRM - Reference Yes

PM2.5

8/29/2000 to

111712007

R&P/Thermal PM2.5

WINS 1,v/Correction

Factor TEOM TPM2.5 - Alternative Yes

PM

rb.ad

Operated seasonally

9112/1990 to

413011993,

MR1/13elfort 1590

nephelometer

NPM 10 - Alternative

NP !0/NPM2,5

Alternative

No

Yes

(NPM2,5siaace

10/1/2002)

Continuously

from 3/22/1916

present

Radiance M903

nephelometer

[lnlics denotes current monitoring instniment and status

In addition to data available through AQS, ORCAA has other particulate matter data For the Lacey

College Street site. This includes this includes nephelometer data dating back to 1990. Nephelometer data

was not submitted to AQS until EPA issued guidance on correlating beat to PM2.5.

PtWl0 Concentrations - f'M t0 was monitored with a FRM from 1985 to 2006. The 24-hour concentrations

are shown in Figure 2 below. Monitored concentrations exceeded the 1987 standard in the late 1980's but

were well under the standard by the early I 990s and have stayed low for decades. The maximum 24-hour

concentration recorded during the last five years of FRM monitoring was 60 μgrm'.

7
Lacey 24-hour FRM Milo Concentrations

(1985-2006)

Figure Lacey Colle>e Street Historical Mho Concentrations

Because P'V1 10 values were well below the federal standard, FRM monitoring was limited to the winter

season beginning in 2004 and discontinued in 2006, when , EPA approved Ecology's 2007 Monitoring

Network Reports. Etic c'rpt Ji'ulttthis repot' aye; _irtelusigd as Apr ell;lix t3,_ORCAA has continued to

estimate Pivl lO concentrations with a nephelometer.

Ecology's 1' llo Correlation - Ecology's statistical analysis of seven years of nephelometer readings and

FRM PM IO value (February 5, 109p to April 23, 2006) found the two were highly correlated, Ecology

then used this information to develop a model to calculate PM1o concentrations from nephelometer bs.t

data.

Model Development - Ecology used hl':A's Data Quality Objective Guidance (DQO Guidance) to

develop the model. While a nephe.loi inter is an alternative method and not a FEM, the correlation still

exceeds the minimum criteria outlined in the DQO Guidance. Ecology derived a Pearson Correlation

Coefficient (r) of 0.88. The DQO Guidance states that 0.70 is sufficient to establish a successful model.

The Ecology model to convert nephelometer values (scattering coefficient or h,, a,) to PM 10 is.

Calculated PM IQ value (NPM l0) = 25.2 bscat + 6.2

Output from the correlation analysis is provided in Appendix R ; Figure 3 shows the high correlation

graphically.

Washington State Department of Ecology, 2007 Ambient Air Monitoring Network Report 2007. publication no. 07-02-011

t EPA-45+a-02-002 November 2002. Data Quality Objectives (DQOs) for Relating Federal Reference Method iFRvll and Continuous

P512.5 Measurements to Report. an Air Quality Index (AQ1)

8
μg/m3 and 2 outliers removed)

2.5000

-0.5000

Lacey FRM PMlo vs Bscat Scatter Plot (<3

70

RZ =0.88

Calculated PM I o value = 25.2 * bscat + 6.2

Figure 3 Lacey-College Street Correlation

PM1D Nepiielosteter Monitoring - Because of the high correlation between nephelometer readings and

PMID concentrations, Ecology and ORCAA conclude that NPM i6 values calculated directly from a

nephelometer using the Ecology model above are a reliable, reproducible approach to represent the PM i6

levels in the TCMA. Ecology and ORCAA have used and continue to use the nephelometer to measure

particulate matter levels at the Lacey-College Street site.

Figure 4 shows NPM IO values calculated from nephelometer data since the FRM was discontinued in

December 2006. The break in the data in the summer of 2010 was due to a remodeling project at the

monitoring site. The NPM 10 values have the same general pattern and similar high winter values as the

FRM. PM i o concentrations continue to remain well below the PM to standard of 150.i.g/m

9
Lacey-College Street 24-hour NPM10

2006-2012

0

12/15/2006 12/15/2007 12/15/2008 12/15/2009 12/15/2010 12/15/2011 12/15/2012

Figure 4. Lacey College Street NPM10 Values -2006-2012

Today the focus of particulate monitoring at Lacey-College Street is PMa..

PYIz, s in the TCMA "rhissubsection reviews PM2; monitoring in the TCMA and the usefulness of

nephelometer measurements of PM2 .5 as a. day-to-clay indicator of air quality, These values are also used

to inform curtailments and to assess continued compliance with the PM. t o standard.

PM2. s Monitoring- PM25 was first measured at ev College Street on October 31, 1998 using a FRM.

Consistent with EPA's phase-in plan for this ilea standard, official reporting to AQS did not begin until

the beginning of the following year. PMVf2 . values derived from a nephelometer (NPM2.5) have been

reported in EPA's AQS database since October°2002 1 °.

2'1-Hour PMz,5 Design b'aiue Estimates - The design value, the metric defined by EPA to determine an

area's compliance with the 24-hour standard, is the three-year average of the 98 t11 percentile of 24-hour

s nephelometer, and are not

the NAA

concentrations monitored

approved for comparison

for PM25 . Because

some of

values

the

are

design

derived fro

values

m

Q at a Lacey-College gtreet iech1iicaTly

- are "estimaates".Tlie data used are as follows;

Design values for the 3-year periods ending in 2001, 2002, and 2003 are based on FRM data,

Design value estimates for.the 3-year period ending in 2004 is based on 2002 and 2003 FRM data

and 2004 NPM2,5 data

Design value estimates for the 3-year period ending in 2005 is based on 2003 FRM data and 2004

amd 2005 NPM2.5 data

Later design value estimates are based on entirely on NPM2.5 data.

1° While uepltelonteter values are available beginning in September 1990. EPA did not allow the reporting of NPM2.5 values to AQS until

2002,when the EPA issued guidance for correlating b,a, values to 1'M_.;,

to
Design values and design value estimates indicate that the TCMA continues to remain below the PM_ .5

standard as shown in Figure 5.

Lacey- College Street

PM2.5 Design Values and Estimates

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011

Figure 5. 24-Hour PM2 . 5 Design Values (2001-2003) and Design Value Estimates (2004-2011)

Based on current monitoring values, the TCMA is in compliance with the 2006 24-hour PM2 ,3 standard.

PM1o Violation Unlikely - Compliance with the 2006 24-hour PIVi3 5 standard of 35 pgfm3 will help assure

continued compliance with the 1987 PM lc standard. ORCAA ran collocated FRM PM 10 and FRM

PM2.5 monitors from 1999 through 2002. ,_Data was sepg ate ciEy seasim;-i7etc-lber to yhrc 7 ti7 _ANiir,ter

and April to September for summer. OttCAA found_a highcorrelation between PM It, and PM 5 $fort d

c^i^ I flat coirl...ar:lrlit milli-ttsred••24-hour values from 1999 and 2000 ,II. The seasonal correlations are

shown in Appendix D. In the wintertime, the ratio of PM; 5 to PM li, is nearly one-to-one. I he winter

model- tttat des k17ea.-this, rcl_aticln hip_is:

i? bl __04 6___Mlo.)--LE}: 3

C'cz t ^^t c c:l, the _PMj 5tanillirtl t _ 1 ? _ _ 1 lt?vcl vy uulcl- h iru to be 3_3

i_1 _33,6 = 0.9446 * 150 u g hrr3 - 3.0531

Given ORCAA's finding, the 24-hour PM2 .S levels in _>:. e critical wrote t ..period would have to exceed

13Q Him', to exceed the P1M l o standard: Then, because of the one-exceedance form of the PM 10 standard,

the-PM2.5 level would have to be exceeded more than once a year, over a three year average, to violate

the PM IO standard. This demonstrates that I'M 2 ; is the controlling standard. `Since the highest IVPM2.5

value measured since FRM PM is monitoring was discontinued in December 2006 was 60 ug/rn - . an

e. cee lance-is hi=ghlyunlikel, t.

11 ORC'A.A I in Coincidental ORCAA. 1;6 day3natitoriu_ from fl 12: 1209 thrciui1126, 260E1fbr 12MPM10 andFRM PM2_5emailfiortr
Current NPM10 and NAII'12.5 Data Availability - NPM 10 concentrations using the NPM l0 model above

are available on Ecology's website l` and can be provided to EPA and the public on request. The

nephelometer values and the NPM 2 s concentrations calculated from them are reported to AQS,

Emission inventory

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 of the PM i o 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, Appendix G-1

provides details.

Emission years and categories - EPA approved the Inventory Preparation Plan (IPP) prepared by

Ecology that proposed use of readily available inforntaiion. This plan is provided as Appendix DE.

Emission estimates in this maintenance plan inventory ,ire from Ecology's 2005 triennial emissions

inventory13 (2005 El) and the 2008 National Emission Inventory (2008 NEI). Thurston County values

from the four most significant categories have been temporally and spatially allocated to the TCMA.

These tour emissions categories were chosen based on a review Of the emission sources in the original

maintenance plan.

Significant source categories - The most significant sources of PM. listed: in the original maintenance

plan for the TCMA were Residential Wood Combustion (i.e., Wood Pruning) and Road Dust from paved

toardst4. Lesser amounts'of PM Lo <mine from Vehicle Exhaust and Tire Wear and Construction Dual. The

same four significant emission categories are included in this attainment inventory. Other sources are

deemed insignificant, including industliat soulces:Outdagl^ Gtl_nine is prohibited in the

:f(

M

emissions wgutd be irrinimal.-Activities in the TCMA continue to be govern-menial, commercial and

residential in nature,

Maintenance Plan Inventory - Washington State's 2005 El is the most recent, complete, readily available

emission inventory for Thurston County for three of the four emission categories. Since neither Ecology

nor ORCAA have local information on omissions for Construction Dust, these values are taken from the

2008 NEI. The NEI Construction Dust emission estimates have inherent uncertainties because the data

was collected nationally and was not developed specifically for a local area such as the TCMA,

Table 3. TCMA Annual and Winter Day PM. i a Emissions

Emission Categories Inventory Source Emission

Report Year

Annual,

tons/year

Tons/

Winter

Day

% of

Tons/

Winter

Day

Road Dust, ^vecl roads only Ecology 2005 237 0.74 20

Vehicle Exhaust and Tire Ecology 2005 58 0.14 4

12 Ecology tvebsite.ltetl? ,.^:. fitttrrb_;_ynrg fs an4;ivg ,:Defauli.lu_itr.

13 wash egtmr State Base Year 2005 County Inventories. Washington Suite Department of Ecology Air Quality Fragile, Sally ()Verson,

June 8, 2007

The inventory includes only paved roads as there are few unpaved roads in the TCMA.

12
Wear _

Construction Dust NEI 2008 627 1.01 28

Wood Burning Ecology 2005 272 1.72 48

Totals 1,194 3.61 100

Based on the 2005 El, uncertified stoves and older fireplaces represented 74% of the total solid fuel wood

burning devices in Washington, Thurston County's total was comparable at 72% 15 for these two types of

units. Since wood burning devices are the most significant source of PM lo, strategies to reduce wood

smoke emissions continue to be key to compliance with the standard.

Control Measures

Wood smoke is the most significant source of PM I0 in Thurston County in the winter, ORCAA and

Ecology relied upon of Reasonably Available Control Measures (RACM) for residential wood

combustion to return the area to compliance with the 1987 PM to standard. Ecology and ORCAA have

continued to implement the control measures included in the attainment and earlier maintenance plans.

The control measures include:

• Curtailment program during impaired air quality

• Certification of new woodstoves

• Rules that govern the sale and transfer of uncertified stoves

Opacity limits

• Fuel restrictions

ORCAA and Ecology rules provide the legal authority to implement, maintain and enforce the control

measures in this plan. They are described below and provided as Appendices E and F respectively.

Control Measures in ORCAA Rules-Washington State's Clean Air Act grants the authority for and

outlines the conditions under which ORCAA may adopt its own rules. ORCAA has jurisdiction over the

TCMA and relies upon its rules to maintain and enforce the PM io standard, The state of Washington

requests EPA adoption of the ORCAA roles listed in Table 4, and tbuncl in Appendix G .into the federally

approved SIP

Table 4. Control Measures in ORCAA Rules

ORCAA Rule 8.1 Wood Heating WI)

8.1 ,1 Definitions - Certified

8.1.1 Definitions - Opacity

8,1.1 Definitions - First and Second stage curtailment

8.1.2 General Emission Standar ls_(h). al_rcl (G)

8. .1.3 Prohibited Fuel Types

8.1.4 Curtailment (a) - (d)

Stage 1 - only certified or pellet stoves

Stage 2 - shall not operate any solid fuel burning device

8.1.5 Exemption;

8.1.6 Penalties

8, 1,7 Safe and Installation of Uncertified Woodstoves

is

4lteison. Sally. Department of Ecology, 2005 I;i, From County llzvicz+,xls

13
Disposal of Uncerlitied ioodsS.2yes

6a,3_tifa__rt lctelati_tI_car I_ira^l_^. I L 1 n. binning, iy xallar ecl_in spa;c.iticd_Eiti s and__ar,_li ; 1.

6.2.6 Curtailment- restricts outdoor burning during curtailment .

6.2.7 Recreational Burning .- none allowed in TCMI

ORCAA's Curtailment Program- The curtailment program has been successfully implemented in the

TCIv1A. ORCAA's curtailment program is key to maintaining compliance with the standard, When wood

smoke pollution impairs air quality, ORCAA restricts wood burning, When ORCAA 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.

Bum bans can be called at 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 I bum ban (First Stage of

Impaired Air Quality) is declared when meteorological conditions are piedicted to cause fine particulate

levels to exceed 35 ltg/tn3 within 48 hours, when measured on a 24 hour average basis. 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 pe e l It i t ion trend. Under certain

circumstances a Stage 2 may be declared without calling a Stage l first,

Since Stage I and Stage 2 burn bans are dcsietted to maintain the more stringent 2006 PM 25 standard,

ORCAA's butn ban rules are more protective of the i?M i r standard than the state burn ban rules

supporting the attainment and first 10-year maintenance plan for the TCMA.

ORCAA Woodstoue Change Out Programs - Over the years, OR CAA has helped many residents within

the TCMA upgrade their heating systems using grants through Ecology. In the winter of 1994-95,

ORCAA successfully helped Thurston County residents remove 143 uncertified woocistoves by offering

a bounty of $100 on each stove. Then, in the winter of 2008-09, another grant program replaced an

additional 90 uncertific l stoves in the area. The latest program, which began in the Mall of 2011, is

designed to replace uncertified woodstoves with cleaner fuel burning devices. This program serves the

TCMA and nth or urban growth areas I'' in Thurston County. ORCAA offers residents who want to replace

wood heat systems $750 toward purchase of gas fireplaces and SI,000 toward purchase of other

qualifying replaaenents. Qualifying replacement appliances include gas fireplaces/gas fireplace inserts,

electric or natural gas/propane furnaces, natural gas/propane heaters/stoves, or electric heat pumps

including ductless heat pumps, This program ends June 30, 2013.

Control Measures in Washington-Rules - Ecology ' s woodstove rules are published in Chapter 173-433

Washington Administrative Code (WAC). Notably these rules include emission standards for new

woodstoves found in WAC 173-433-100. Washington State has one of the most protective woodstove

emission standards in the country. Since January 1, 1994, new woodstoves must meet a 2,5 gramsIbour

(g/hr) emission limit for catalytic stoves and 4.5 g/hr for all other (noncatalytic) stoves. EPA (which is

working on revising its standards) set standards of 4.1 g/hr for catalytic stoves and 7.5 glhr for

noncatalytic stoves in 1998.

I colo>?y_i requs:s,tin 1& letinrs on t[ae,_Scctit7tts pl' 173..-433 jts.liyted in_Dble 5 below,

ie Expected growth areas or incorporated cities of Thurston County established under the Growth 4[anagernent Act.

14
Tttble_S=R.egiictcILP;ti,roctii^a7_u€i_ChGtf^tsr us.I..,F...r..i3e„ic.c:

Section and Titac State

effective

E1?A

effective

State

revision

^ ttttc

revision EPA

slate (ate (V(_`tilnQ) _t.lfif_ctty_'

Ole

atlipa

173-433-030 Definitions 10'18190 111593 Yes 420,91 App ro i. al

173 ,4.33 . 100 Emission 10.E 13:. 90 1!1593 Yes 3/6'93 Appms al

Performance Standards

173-433- [ 10 Opacity I {)11419() 1 ' l j/93 Yes 3.6 93

Standards

173-433-120 Prohibited Fuel 1().I 1 <8.^90 1 115`93 Yes 4'20,91 Arm) vi:il

Types

_173-4:33-[40Impaired air New 4/20/91 Appmsal_

t€alit' tena

I73-433-150 Curtailment 10/1<3/912 lil5793 Yes 4?20.='91 Appro

I i3- &33 170 Etetail s€tles fee 1/3/89 I/15,93 Ili? tti a

Lzulggy requests EPA approval of 1x.,5 tiocl- cif:- t .c. l.3-43 3. 1-#ive-hree .sections of the WAC that

were erfe•etive.-revised on April 20, 1991 and two additional sections were, effective revised on March (6,

1993. Bic se -fivve sections of the WAC update Ecology rules. that were prew . iouslvapproved by EPA and

aodhs.catrr. etfuntive00-January 15, 1993. One,ccuion Vb":W 17a-43.3-140In1p7_nl_edI. 1r(l€di

Criteria, also approved by the state in April 1991. is new and has not previously been approved by EPA or

adopied into the federal SIP. EPA approval of that; seven .si c sections of the WAC will strengthen the

state rules in the SIP,

The atztte of W'.sshing!enEco1ogy; also requests removal from the SIP of WAC 173-433-170 Retail sales

fee, which was approved by EPA and effective January 15, 1993. This section of state rules is not a

control measure but a legislatively mandated fee on wood stove sales. EPA approval of state-levied tees

for state purposes is inappropriate and this provision should be removed from the federally approved SIP.

,l^pcttcltx,fl.,isst,strikcfu€at4xrr5anzi,al,_t(lctrl^.rl][}^^lctY,cli-.tn G^ inucEPr'elstst nwccl- 1L;.sl1...I.i^_Ii. '.s

rules into the federalS1I up throughtheMarch €, I 993 rs visions.

Contingency Measures

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. ORCAA's Rule

5,1.4 (e) provides for prohibition oftl .c us ,of uncertified woodstoves in the TCMA for the sole purpose

of meeting CAA requirements for contingency measures. To implement this provision, the rule

4_7_(earegpire_s_that ,the EPA, in consultation with Ecology and ORCAA, must make written findings that:

(l) The area has tailed 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

(3) A prohibition issued under 8. I.4(e) shall not apply to a person that does not have an adequate

source of heat without burning wood

(4) The area consists of all areas within the city limits of Lacey, Olympia, and Tumevater and

. unincorporated areas of Thurston County lying within or between the municipal boundaries

Comment [DS1I l anuguage revised Sc track

is
Contingency Measure Trigger - The contingency measure will be triggered if a violation of the PM to

standard occurs at the TCMA monitor based on nephelometer aar^elWor E.K.M.,..monitoring. A violation of

the PM lc standard will be determined by the procedures outlined in 40 CFR Part 50, Appendix K -

Interpretation of the NAAQS for Particulate Matter.

Commitment to Continued Monitoring

EPA considers continued monitoring especially important in a LMP area because there is no cap on

emissions, Emissions in the TCMA are not expected to grow enough to threaten compliance with the

standard as discussed in Section 3 of this plan.

ORCAA makes a commitment to continue operation of.a nephelometer in the TCMA through the 2020,

the end of the maintenance period, to determine PM to levels.ltt. _tlt €uzl>k Iy^. c:rtc^tat Malarfler. l^; iic^n^t

ctivtti ;art cli cguriteci tl ii<}ttil rtigltl st 1? 1Tt conci n€r atican iri a c alei^ l ix^ {<3iit tba

irtisnttcoritnK xc.eeds tits I_ IP thresh ld ot. 9 .E .ln_. Eclalo';yb L)RE .1 ., rtul_EE'r1, uti_c is.u

a.s E5t tltli:.,hm nt_E„ (ttoniloun^z_as p trl_Ui t1_t. ,. annu l i Ltnork i ;nttotttr ..r port•p1O €.".' PMIo

concentrations are available on Ecology's monitoring wcbsite i' and can be provided to EPA and the

public on request.

Verification of Continued' Attainment

ORCAA will calculate the TCMA P!i'vlj design value estimate annually from nephelometer data through

2020 to confirm the area continues to meet the PM 10 NAAQS. A 3-year NPM IO design value estimate of

or below 150 pg/m7 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 TCMA based on the

NPMI0 values.

Summary of Mamtenance Plan Commitments

Commitments made in this maintenance plan are summarized in Table 6.

Table 6. Second 10-Year LMP Commitments

Section Commitment Responsible

Agency

3

eene

Annual calculation of the TCMA PM. ID design value estimate

through 2020 to show continued qualification for the LMVIP option.

ORCAA

3 Reporting to EPA on continued qualification for the LIVID option

in the annual monitoring network report

Ecology

7 Implementation of the contingency measure if the TCMA violates

the MID standard based on nephelometer monitoring

ORCAA

8 Continued nephelometer monitoring of PM to in the TCMA ORCAA

17 Ecology websitz } tqz,., ,. Eyim,,: .n !.,^y ti ea 4_et3 tw tk S Guit; tnl:^; ORCAA monitoring data can be requested at:

http! data.oo aa.org request-datar

15
through 2020

9 Annual calculation of the TCMA PM i c design value estimate

through 2020 to assess compliance with the PM 10 standard

ORCAA

9 Reporting to EPA on continued PM i o attainment in the annual

monitoring network report

Ecology

Required Plans Complete

The TCMA was redesignated to attainment for the 1987 24-hour PM i o standard in 2000. EPA approved

the first l0-year maintenance plan in December of 2000. This plan ensures compliance through 2020 and

Mills the final requirement for maintenance plans specified by the CAA.

17
Appendix A. Limited Maintenance Plan Qualification

Design Voltlea

The TCMA ped :llai . l e- tTcltce.- .c;thod :ti R )design value based on C_l _M 24-hour PMra monitoring data

from the College Strcct site in Lacey, Washington. The LMP Guidance directs the design value be based

on tltc most>^^cnt five years of data'. " ;1ic. 11J^5t re;cetat_(ive;kc<trs ok'1_.€Zl^ _ dat_a_i5 fict^;ti ,2Q(11 -2{)Q5;_tlt

most recent data from an alternative method, main, a ucrphelometer i5Ilom 20{)8-2012.

Fit:Ill7:11g/I YoI4 F'

The PM ID SIP Development Guideline' CSIP Guideline) stipulates that the design concentration be the

maximum Wiest value for data sets of 347 or fewer values. 5irtc:ethu_F .IVI.,_cisata_;t t„1 15 fe} cyr thztn_3_ 7

values, the de',i v ,alpe is 60 Itgitrm'- the hieliest value From 2001-2005--Pherefor-m,-thede ign-value frn

. ! l ritt'-based-on the maximum ce3aeatr-atdon-1Ie ' n r ^ &

0giwt,'t2i;TiCtM ::t?€ € Fs ^lonobsei€^>r,aThe relevant values are shown in Table A-1 below.

YEAR

ANNUAL

NO.

OBSERVATIONS

MAXIMUM

MONITORED

VALUES,

}s'tn?

5-YEAR

PERIOD

YEARS

NO.

f)It5t.1tVAT[ONS

5-YEAR

MAXIMUM

DESIGN

. _ VALUE, 1tt^rul

1999 60 38

2000 60 47

2001 61 60

2001? 60 46

2403 60 42 1999 2003 301 60

2004 37 E40 2000-2004 278 60^'*

2005 36 32 2001-2005 254 60**

"Design value reflects wintertime seasonal sampling which occurred from Jan 2004 through April 2006.

(Iterrt:atii e tll tlacrc I csi n.. Valucr,.l strrsarrtc

EZi nx^nltl^rrp}w is til^cntlnuGc_G1t_2t)C5 hcc:1. ttsc. ['el l n.yluca_wGrG_y.;el, l . bt;lo^v_the fe^1^1. 11_i ,tttclrtl:

ORCAA continues to estimatePM. ,J) concentrations from nephelonterer values (NJIM 10). Since

nc:.p19l9cn 9tcr values ale lac?Lt.9 hntcrtll^ .tap}2rUVC.cl fgrc lnpaaasgn , tca. tPie .AA.QS lgn valley

derived Rpm this alternative methodisan "estimate".-the SIP Guideline directs that the design

.p_tacisntration used fQf clptasets vitli. 1,391 _1. ,73. _y<tluts_l?c this fifth, highest.,taiuh, The design_vtttuc

L4IP Guidance. pp 3.

` Tabular estimation method From PM-t0 SIP Development Guideline. publication EPA 450,2 86-001, Table 6- I, pp.6-5.

18
stitzt;,itu .a. i_n ..t^,t __t..'?;3 N P ^'C 10 value, 9i n.. 2i)OH.=.?.t) l2_i ._ .?_.ga m

5itlc.c 1ha ^ntlt thc_^ ^ Ealt „; tt_c, ^A I tti^, ^a r j71' tti y_llt3c_stipulat cl_. ic^_tl^ I._!1P_gtlicli nu the

I(`, E.A.tt;ee t. tht ..cx^tld tk)i , .

Motor Vehicle Regional Analysis

To qualify for the PM to LMP option, an area should expect only limited grown in on-road motor vehicle

PM to emissions. This means the area must pass the Motor Vehicle Regional Analysis, found in Appendix

13 of the LMP Guidance. The result of the analysis must be less that 98 (tg/m 3 , the Margin of Safety

(MOS) value for the 24-hour PM 13 standard.

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 TCMA and threaten the assumption of

maintenance that underlies the LMP Guidance,

DV+ (VMT,,; x <MOS

Where:

DV = the area's design value based on the most recent 5 years of data, .Lg/m3

VMTo = The projected percent increase in vehicle miles traveled (VMT) over the next 10

years

DVt,,,.= Motor vehicle design value based on on-road mobile portion of the attainment year

inventory, Ixg/m'

MOS = Margin of safety for 24-hour PM-10 standard is 98 sg/m 3

Step I. Determine the S-year design value (DV).

The maximum from five complete years of data (2001-2005) as shown above is 60 pg/m'.

Step 2. Determine the percent increase in maintenance area average daily Vl'IT over the

next ten years (VMTJ,).

The VMT data for the TCMA for 2010 and 2020 was supplied by the Thurston Regional

Planning Council (TRPC)3 , The percent increase in VMT was calculated by calculating the

difference between 2020 and 2010 VMT per day and determining the % change. VMT

values are:

2020 3,283,767 miles per day

2010 2,809,324 miles per day

10-year increase = 474,443, miles per clay

Percent Increase ( VMT,;) 16.9%

Step 3. Determine the motor vehicle design value based on on-road mobile portion of the

attainment year inventory (DV,,,,).

Thurston Regional Planning Council, 201 I Amendment 1e the Thurston Regional' transportation Plan, adopted June 3, 20I I,

page 4
The third paragraph of Attachment B of the EN/1P Guidance offers: "Please note that DV,,,^.

is derived by multiplying DV by the percentage of the attainment year inveutot•v

represented by on-road mobile sources. This variable should be based on both primary and

secondary PMio emissions of the on-road mobile portion of the attainment year inventory,

including re-entrained road dust. ,,

Table A-2. Onroad mobile PM 1 a emissions, Ecology, 2005

Category

Annual,

tnnsryear

Tons/

Winter Day

% Winter Day

_ Total

Vehicle Exhaust and Tire Wear 58 0,14 3.{}

Road Dust, paved roads only 237 0.74 20.0

Total 23,9

Total On Road Mobile (ORIvI) source emissions from Vehicle Exhaust and Tire Wear and Road Dust

from Paved Roads are 3.9% and 20% of the TCMA 2005 winter day emission inventory, respectively.

This makes the percentage of the ORM inventory 23.9%..°.,

DVm, = DV x % Onroad Emissions

Therefore:

DV,,,, = 601.. 0..239 =14.34

Step 4. Calculate the Regional Emissions Analysis Margin ofSafety (TWOS).

The variables and the values for the equation are shown below:

DV+VMT2;xDV,,,,. = MOS

60 + (0.169 x 14.34) = 62

Step 5. Compare with MOS of98 fag/m 3

62 pg/m3 <<98 pg/m3

Since 62 pg/tn; is much less than 981.tg/m3 , the area passes the motor vehicle regional analysis and

qualifies for the LIvIP approach.

20
Appendix B. Ecology 2007 Network Report/EPA approval

P'/Q. 7flei'l cork Report.f!itfj o Si:0m

ThefollowingAppenslix contains Section 1.5 from the Washington State Department of Ecology 2007

An b ien ,\ i rj oils _Report, 1 ibis portion of tltc , Report ... in

PM 10 monitoring ibr that year, 'i he_ letter from EPA approving this report lollow

4,5 Partjiu late after (PNI I",81W.D

N.i:13-i,id........ V)13.7.:

• Twcntv-tOur hour awl-age PM L. concentration not to cxeced 150 ag/m ' on more than cine occasion ma. veal .

when averaged over three vents.

®_„,,,,,, aiiriick

aoilution the EPA revoked the an

-

nual PMA standard in 2006 (effective December 17, 2006).

WishingloW. s ni.in.yLrk c €l lists of elev,KpAitg. 2akwde.

43 Particulate I% latter 10 I'M! 0, 31102

T21P.P. ^ClijQ Snnipjim

T'Pe 2007

53{1;32004 5S7 SLAMS kl_tahbol hood Continuous onlv Cuntinuc

530330057 i ST.A?<lS Nei ithbui hood Continuum onl Continue

53053003 1a)oMuod Continuous on v 'eon nue

5307300,11 Neigh orhmid Discontinued pjscontin tied

330670013 Neighborhood Discoutitt9ed Diseon tin ned

110 0 13 Neighborhood Disconnime Moon tin nod

...... n:9A- 1 ..... Co trrucius only Disc. F

5 3_0'i' ()(}49 It,igightgthg tcl t& 112int,ER NI

5AQZ110....QE StEIERItSECle111}Iri'lsrJii x'15 /98 SB, ;RTES O II borhoot DiseJatitilmd.

i3j)ff_DIA. IL(Li V6g111m 121y,.ED.11

5.1112100, l' !ei gith0und Jli .,

s,

cgtmljiiued Disci FRM

330710)06 MisLck nt[mom_ o he, RNlt

,{L(a a oo 1 6

-

4. Middle Contjn ions & Continue both

in

SULU)k i :L72

(:'n-lo

Ni O.& Continuum

1.16

Continne both

530O.N004 SLAMS Neighborhood Discontinued Disc. F

ANiiju-Et.1M .... LtLyn.;i '\19die

Recommendations/Pro )osed Modifications: Washington State discontinued ParticalkyLlyfatter 10 F'RM operation

0tAg

-

. Q.p. e.11t6.1ri of, _LGlu 10 con options d c es

!EE.y.grkis

continuous device and comlation whit an FRM is undtirtay. A t_$Aullyside,phe PM! 0 F'RM and platkirm was

daLmejLidl.)yt(igli ikiuds DecclOcr 2006.-It t lte replaced.

21
Kent/Central & limes - SLAMS

AIRS 4 5303.97.,004

Adthe as 2()3 I asl StnOh Starel (James_Sueet__& C.'rn it At;eti_ue3^Kent

I.,A"C/LC)NG: 0E23' I0" / 122 13' 55"

Aideq uncg

Cciin_rt Jatn is_a Jie_ igill)oncoc7d sidle site IprN11.0... nIg 7li5liec1ira_-i_9£i7 lr i=lgcated in to to ixt cf

cattttnercialrresidenlialarxc in Downtown Kent.

f^xcecrlcttcctc

1.'his site has not exceeded the stan tdard for PM 10 in the past 3._years.

Jassyetionforcontinued monitoring

The f cnhatl..^i " James I' 1 tlJ cod tit^lintts_cf^vice is c crnt xi is 1^5^r€ t^l t12 .J jitil7tci^an...I Lbn firr the Pu t,S ^t^n i,.

Seattle/Duwanaislt - SLAMS

AIRS 453()330057 ^^_

Address; 4752 East Marginal i'vav,

South. Seattle

LAT/LONG: 33' 31 l2

.rderritucw .,_..,

Jinuannfsh ,is „i„nu4hburhtspci,_scal_c.,sift. for. Plv[10_cstsbhs tec1 - tn 197. 1.: _It, is..1o ales! tnib„uttittl rci , tl/tndustt.ial_. _i.rea

south of downtown .Seattle.

L'xceedences

1`Itis._site liar_not,

cfuci tli stzttz..f 21(1. its flu; asi...ears,

Justificationfop contiataied eioaaitorirt„g

The 1711t1,4i ush PRi1S) tuntiraizP.g!i ct5rtce..i. operated itsport_cftfie uiai 1-115Tnt3c e nltat. for the -Pti;et S.9.g.i.

IS_eSnnewkk/[4enneivick VSC.'- SLAMS

FURS 4 5.30050002

Adiress:_502West_MetalinexI; emiecv_ic.l:

1_. "li •,(ONG: 0=16 13' 06 / 119 l?.' C^3

eltlctiuaot:

K,1 nits wirt< is ¢t ne iihnrhoocl_scale: site for PM;I_0 , estahhshed in199)^l_ (I is located in tl_ic clowt town 1Cri31ae^^ ic1

A credences

Ibissitu- hasnotexclu excluded _Owl; rttl .. for PM 1.0 "0.

Jul i(icath n. (hr continued monllord

71w Kennettvi;;ic ^ite..is. rGpr scntatrsc c,f dre_Kennewit K.enutessak a .ea is sizl;ie dust.

Yakima/Yakima -rental Health -. SLAMS

A1RS 4 5'30770005)

(i(II: s_.402_South 4'r Aveuue,1(afkint_t

A.'. LONG: 046 35' 4?" / 12{1312 44"

Adgtract,

Yakiinn_Mental E1eailli is a nc.ighborhoc ti_sak. sitc_.fot'.-PM Musk* hshed ia20 )o i^ as loc5u 1" in

colrtmerc. il_ estdentittl area n .Do

di.rceealentces

t:3.5itg. 1R*..itc^t. exc:et.dg:l_ihe,cl lily. g..a tl....-sa<trtcl513Lf :tr_p .L.Qin. tltc_)3rrst 3." vc_:1rs_

Jussdficraniorr fin. continued monitoring

The Yakima Mental Health site is representative of the Yakima area, Yakima has beets Particulate Matter 10 nontltlaimtnent area.

22
Colville/Colville -SLAMS

53Q6500 04

Ad 215 South Oak, Colville

LATLONG: 048 32' 41" / 12254' Lr

Adequacy

C'oivitl4_is-_ .Heir )) ........ .otO ... It area . tot'

Colville.

...........

This site has not exceeded the standard Ior PMIO the past3„nears.

justificationforcontinuedmonitoring

Ecologv hasdiscontinuedthe Colville PMI 0 FRM.

Wrdht-Walla/Walla-V1 alla Fire Station - SLAMS

AIRS # 530710005

Address; 200 South 12' 1',Walla-Walla

046 03' 12'' ..I 2 Pk''

Adequacy

WtIlla-Wal la Is ....gjIl2pthood site 10 esttibiAigtim 989... It Is Ioetned tt commereialLre I_

Exceedences

DiLsite has not exeeeqedlhe .. Coi PM I 0iiLthmasil years

Just/ /ration o rout/ ue monitori^x

diseaptintted Lit2ijigy. the Wlilla-11

Ala P.M 10 Fad l:

Burbank/Wallitht - SLAMS

AIRS'520:7Elftt16

Adthi::!712551Maple

LATLONG: Q4611 00 / J1.2J)OLS!

Burbank is _a rnidslig...i,:Ali.gAiL . . RMLOs_t,trabjishct .irt 002. .. .h;i1t,.giilutts11Ts . .i_e1erltil areAsliltEN-Ink.

The 13tyll,als1l,YAllala site has not exceeded the standard for P 110 in the past 3 „vent:,.

Justification

LIKBIrban ...akls23jthinthe

Burbank PNIIOFRM(.

Spokane/Crown Zellerbach -SLAMS

AIRS ti539ODDlo

.d.cirgi.E. 3 UQ.Fq.112.,.: .arsgb..apAuK

LAT/LONG:11EIT19fLaLILX

Adequacy

Crown 7ellerbachisnliddle scale site for PM10establishedin 1972. It islocated in a highN trayeledenirimerejA

,x,ert of5ppIcane.

Carr taienees

This site hililig.0ceeded this: A.ii-xialtir.TM.112jitAste_i1rasLi.mrs.

,htst' wade or continued monitor/us,

The Crov% n Zellerbach site is representative of the Siloka tie area. Spokane is a mist Particulate Matter 10 nonLntaimnent area.

23
LAPLOINC - 40

,415571 1 17,05(1'727

Adewulto

glarltstdla,

Ewen-knees

This site haslIgI exceeded the standard fin' I'M 10 inihepast 3 years,

Justification forcontinued monitoring

pi a-u_

wood smoke and mob,ile sqproes. Ecolotty is dlscoutlnnetl the Clarkston ['MI 0 FRM. Ecology has established a

AIRS -4.530730015

LATILQNO .,P_43 4Y 401 IN 6' 25"

70 3

ldr-

ord. A .. ';05 East 4 ''LP lair! Van .. itycE

'L ONG. k)45 38 53" 1 122 35 u

24
EPA Approval Letter

25
Formatted: Font: (Default) + Body, 12 pt,

Italic

UNITE[? STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 10 .' .

1P.00 Sixth Aveeuo

Seattle, WA 0101 .

NOV 16'M7

OAWT-107

Mr. Mike Ragan, Air Monitoring Coordinator

Air Quality Program

P.O. Box 47600

Olympia, WA 9l504-7600

Re: 2007 Washington Ambient Air Ivlanitoring Network Assessment

bear Mr. Ragan:

We have evaluated the 2007 Washington Ambient Air Monitoring Network Assessment

and Ecology's proposed air monitoring network for 2008. This network assessment proposes the

following Changes to the Washington ambient air monitoring'network that have mewed since

EPA's approval of the 2006 network assessment:

1) CO - The Vancouver CO site was discontinued on 9130106. It is proposed the CO'

Bellevue (148°') and Spokane (3` a & Washington) sites in Washington he designated as

SLAMS sites. .

2) Ozone -,The FCC Loomis and Wishram sites have been discontinued, The remaining

ozone sites in Washington are recommended as SLAMS with one exception. The Seattle

*Beacon Hill is recommended as an NCore site.

3) NO2 - Ecology has ceased operation of the Beacon. 11 l! N02 monitor. Trace level NOy

has been established at the Seattle Beacon Hill site.

4) SOP - The Seattle. Beacon Hill 802 monitor leas been discontinued. Traee level 502 bns

been established at the Beacon Hill site.

5) Ecology has discontinued operating all MI O FRMs, except at the Yekinna and Spokane

Crown 2 sites. Operation of equivalent method PM10 continuous devices are in place at

all remaining locations. At Clarkston, the PM10 FRM has been replaced with a PM2.5

Continuous device and correlation with a PM2.5 FRM is underway. At Sunnyside, the ,

PMI O FRM and platform was damaged by high winds in Decetuber 2006. It will not be

replaced.

6) PM2.5 Fk144s at Vancouver and Yakima were re-established as of 11112007 because.

PM2.5 design values at these sites are close to the new PM2.5 24-hour standard.

7) P1v12.5 speciation: The Olive Street and Duwamish speciation monitors will be relocated

to the following locations by the end of 2007:

a) Moose Lodge, 8205 E 4th Plain Boulevard, Vancouver, AIRS 11530110013

b) Comprehensive Mental Health, 402 South 4th Avenue, Yakima, AIRS

#530770009

These changes are consistent with the network design criteria identified in 40 CFR Part

58, Appendix D. I therefore approve these changes.

Pi nieaonAvcy,loaPaper

26
Formatted: Font, (Default) +Body, 12 pt,

Italic

2

The following monitors are designated "core" monitors because they are either: 1)

required by hi) CR.F Part 58, Appendix D; 2) have a design value near or above the new PM2.5

24-how. standard of 35 ug/m3; or 3) they are essential monitoring parameters at NCore sites:

1. Flvf2.5 FRMs (or Approved Regional Method):

a) Beacon Hill

b) Duwamish (ptimaty and co-located)

c) Crown Zellerbach (primary and co-located)

d) Tacoma/L Street

e) Darlington

t) Marysville

g) Yakama

h) Vancouver

2. PM2.5 speciation monitors:

a) Beacon hill

b) Olive- Street (to be moved to Yakama by the end of 2007)

c) Duwamish (to be move to Vancouver by the end of 2007)

d) Tacoma

3. Pre-cursor gas monitors at the Beacon Hill NCore site

"Core" monitors are those monitors in the network that must be operated with available

PM2.5 monitoring funds. The "non-core" PM2.5 monitors hi the State's network can be

operated at Ecology's discretion with any remaining federal or State funds.

If you have any questions about our approval of the Washington monitoring network,

please contact Keith Rose at (206) 553-1949.

Sincerely,

T(tAJ44 L

Mahbnbul lslam, Manager

State and Tribal Program Unit

cc: Chris Hall, ()EA

Keith Rose, OAWT

27
Appendix C. Ecology Correlation, PM 10 to Nephelometer

Ecology analyzed the relationship between nephelometer readings and Federal Reference Method (FRM)

PM ]c concentrations for seven years - from February 5, 1999 1 to April 23, 2006. Ecology used EPA's

Data Quality Objective (DQO Guidance '

) to develop a model. The analysis showed that the nephelometer

data correlated well to the FRM data, Ecology derived a Pearson Correlation Coefficient (r2) of 0.88,

which surpasses DQO Guidance identi tied minimum specification of0.70 3 .

Calculated PM,0 value 25.2 * (b sea,) + 6,2

Comparing calculated PM I0 (NPM10) to FILM PM I6 - 1999-2006

SUMMARY OUTPUT

Regression Statistics

Multiple R

R Square

Adjusted R

Square

Standard

Error

Observations

0.939057793

0.881829538

0.881510192

2.762976502

384

ANOVA

SS XIS F

.Sign ficauce

F _J_...

Regmssian

Residual

atu!

382

383

21761.73194

2916,202956

24677.93.40

21761.73

7.634039

2850.618 3.06890-179

Caefichute

Standrtrd ^-

_

P-vahte

Lower 033per

Error eStat Lower 95% Upper 95% 95,0% 95.9%

Intercept 6202619631 0.210018104 29.53374 1.2E-100 5.789683413 6.61555585 5.789683413 6,615555349

X Variable 1 25,1957634 0.471908701 53,39118 3.10-179 24.26789961 26.1236272 24.26789961 26.12362719

While nephelotneter readings are available earlier, the values were not reportable to AQS until 2002, when the guidance for correlating to

1,'M2., was issued.

g EPA-454E-02-002 November 2002, Data Quality Objectives (DQOs) lbr Relating Federal Reference Method (FRM) and Continuous

PM2.5 Measurements to Report , an Air Quality Index AQI)

3 Ibid. pp 13

28
Appendix D. ORCAA Collocated Monitoring

This graph shows the close correlation of PM2 5 -to-PM IO in Lacey. This plot shows coinciding daily

averages of PM25 and PM 10 by season - winter is October to March; summer is April to September, The

1 data used in this analysis were collected between 1999 and 2000 using FRM, gravirnetric filter analysis. r

1 Comment [ralhmZ]: Needs title

Formatted: Font (Default) +Body, Bold

0 10 20 30 40 5.0

PM10 [ m

45

-3

29
Appendix E. Emission Inventory Documentation

Ecology developed an inventory or annual and winter weekday PMro emissions estimates forthe LMP. In

the original maintenance plan, all sources of PMro were included. For this LMP, the four most significant

sources in the original plan were inventoried: Residential Wood Combustion, Paved Road Dust, Onroad

Motor Vehicles, and Construction Dust. Other categories inventoried in the original maintenance plan

were deemed insignificant, and were not inventoried.

Ecology's 2005 triennial emissions inventory (2005 El) was used for all categories except Construction

Dust. Since neither Ecology nor ORCAA have local information on emissions for Construction Dust,

emissions for this category were taken From the 2008 National Emission Inventory (2008 N El).

The 2005 El estimates were available as annual and winter season emissions for Thurston County. The

2008 NEI estimates were annual estimates for Thurston County. These estimates were temporally

allocated to a winter weekday, and spatially allocated to the nonattainment area as described below.

Nonpoint Sources

Residential Wood Combustion, Paved Road Dust and Construction Dust are nonpoint sources. These

emissions are typically estimated by multiplying an activity level, such as wood combusted or Vehicle

Miles Traveled (VMT), by an emission factor in mass per activity.

Emissions = Activity level x Emission Factor

Estimation methods and data sources for these nonpoint sources are described below.

Residential Wood Combustion

Residential wood combustion (RWC) emissions are based on the 2005 Emission Inventory. RWC

consists of home heating and recreational use of woodstoves, fireplaces, fireplace inserts and central.

furnaces. Activity parameters for the 2005 El include the type of wood burning devices [certified

(catalytic and noncatalytic) woodstoves; uncertified woodstoves and fireplaces], the amount and species

of wood burned from each device and seasonal, daily and hourly usage rates. Most of this information

was obtained through WSU's Wood Burning Stove Survey for Idaho, Oregon and Washington State

(^VSU Survey 2001). Emission tractors were taken from AP 42, the 2002 NEI, and the particulate matter

size distribution from the California Air Resources Board (CARB).

Wood burning devices include central furnaces, fireplaces, pellet stoves, and certified and uncertified

woodstoves and inserts. Close to three quarters of all wood burning devices in the state are fireplaces or

uncertified woodstoves and inserts.

Table D-l, Solid Fuel Devices, Washington State and Thurston Coun

Thurston County Washington State

Fireplaces 22,126 705,985

Uncertified woodstoves and inserts 12,130 272,103

All Devices Total 47,444 1,320,959

Percentage, fireplaces and

uncertified stoves and inserts

72% 74%

30
Paved Road Dust

Paved Road Dust emission values for paved roads are based upon the 2005 El. Average Daily Vehicle

Miles Traveled (ADVMT) for Thurston County was estimated by Washington State Department of

Transportation (WSDOT) through use of the federal Department of Transportation's Highway

Performance Monitoring System (HPIvIS)I , HPMS includes a system of traffic counts collected over

several urban and rural sampling areas. The Paved Road Dust equation in AP-42' was used to calculate

emissions, Both the 1995 and 2005 emission inventories excluded Unpaved Roads.

Construction Dust

Construction Dust values from EPA's 2008 NEI 3 are used because neither ORCAA. nor Ecology has local

data for this category for 2005. The 2008 NEI data includes construction dust in three categories:

Industrial/ Commercial/Institutional, Residential Construction, and Road Construction. It should be noted

that top-down inventories such as the NEI have inherent uncertainties because data is collected nationally,

and was not developed specifically for a local area, such as the TCMA.

Onroad Mobile Sources

Onroad mobile source emissions are those generated by operating vehicles on public roadways. The

activity measure for omroad mobile sources is the number of miles driven. Emissions from fuel

combustion, and brake and tire wear are estimated based on the 2005 El.

Average Daily Vehicle Miles Traveled

ADVMT for Thurston County was estimated by WSDOT as described above in the Paved Road Dust

section.

Emission Factors - Tailpipe Emissions and Brake and Tire Wear

Onroad mobile source emissions were calculated with EPA's Mobile 6.2 model. Emission rates in grams

per mile were generated for unique combinations of month, vehicle type, pollutant and pollutant type

(exhaust, evaporative, brake wear, tire wear). MOBILE 6.2 uses a combination of default and local input

data to estimate emission factors. Local data was used for the following input parameters: evaluation

month (age of fleet), registration distribution, temperature, humidity, and fuel parameters for Reid vapor

pressure (RV'1'), fuel program, and diesel sulfur content. The parameters are described in Section 3.3 of

the 2005 El, The model parameters and data sources are listed in Table 2-2 below.

Table D-2 Mobile 0.2 Model Parameters and Data Sources

Parameter' Data Source

Temporal allocation to month and day of week WSDOT

Reid vapor pressure

_

Fuel surveys from Alliance of Automobile

Manufacturers and TRW/NorthropGrumman

Diesel sulfur content Western Regional Air Partnership (WRAP)

Temperature and humidity Olympia airport meteorological site

Vehicle age distribution State Dept. of Licensing, State Office of the

Superintendent of Public Instruction, Federal

Transit Administration

12003 I11'MS Mileage and Daily Travel Summary. Washington Sla[e Deraurment of Transporialiun. July 2006

2 Compilation of Air Pollutant Emission Factors. Volume I. Stationary Point and Area Sources, AP-42. Section 13.2.1 Paved (11 . 06) and

Section 13.2.2 Unpaved r11 06).

General Purpose Release version 1.5

Ecology 2005 El, Table 2-2

31.
Spatial Allocation Methods

Spatial surrogates were used to approximate emissions inside the TCMA from county data. For sources

without specific coordinates, spatial surrogates were used to approximate both the location and magnitude

of the emissions. TCMA emissions are estimated as:

ETCMA = Ecounly 0' SurrogatercMA / Surrogatecaunty

Where ETCMA=emissions in the TCMA, Ec OL,,,ty = emissions in county,

SurrogatercmA = surrogate activity in the TCMA, and Surrogated,,,,,,, == surrogate activity in county.

The spatial surrogates and data sources used are shown in Table 3-1 below.

Table D-3 - Spatial Surrogates'

Sector and Category Baba/ Surrogate Data Source

NON POINT SOURCES

Construction Dust -

IndustriallComn^ercial/institutional,

Residential Construction Dust

Population 2010 Census

Construction Dust - Roads Road miles Thurston Regional Planning

Council

Residential Fuel- Wood _ Population 2010 Census

Paved Road Dust Road VMT Thurston Regional Planning

Council

ON ROAD MOBILE SOURCES

All Vehicles Road VMT Thurston Regional Planning

Council at_

Temporal Allocation Method's

Annual emissions data were adjusted to tons per average winter clay for the maintenance area for each

source category. Methods for each category are described below.

Residential Wood Combustion

For residential wood combustion, seasonal activity fractions from the WSU survey for western

Washington were used e to calculate emissions ibr a winter day.

Onroad Mobile Sources

WSDOT provided monthly ADVMT adjustment factors based on 2005 traffic counts] The factors were

used to calculate winter day VMT. The winter emission factors calculated with MOBILE 6,2 were

multiplied by the winter clay VMT to estimate emissions.

2005 El. Table 3- I

6 2005 Cl, Table 3-53. page 63

' Email From Gaoroug Liu, Washington State Departutcut or Transportation to Sally Ouersou. Washington State Department of Ecology.

Transmitting spreadsheets with monthly, clay-ot=week, and hourly adjustment tractors. motttltfac -all.xls. dowl 'ac_all.xls. hourfac_all.xls,

Sept. 5, 2006.

32
Road Dust

WSDOT provided monthly ADVMT adjustment factots based on 2005 traffic counts, The factors were

used to calculate winter clay VMT on paved roads, Winter emission factors were calculated assuming no

rainfall, and therefore no moisture adjustment. The emission factors were multiplied by the winter day

VMT to estimate emissions,

Construction Dust

Construction Dust values are from EPA's 2008 NEI. Activity Adjustments for Construction Dust are as

follows,

The EPA NONROAD2008 model for Construction Equipment allocates 20.7% of construction equipment

activity to winter (SEASON.DAT tile). Construction equipment is assumed to operate 6 days/week. The

total winter day emissions are calculated:

T/day = (T/yr x 0.207) / [(6/7) * 90 days/winter]

Temporal Allocation - Additional Adjustments for Construction Dust

A further adjustment was made to construction dust emissions to account for higher soil moisture values

in the winter. The NEI dust equations contains a multiplier of 24/PE where PE lathe 30-year average

precipitation-evaporation value from Thomthwaite's PE Index. A variation of Thornwaite's

precipitation-evaporation equation (below) was used to calculate PE by month using 13 years of

temperature and precipitation data's from the Olympia Airport meteorological station. The calculated

monthly PE values for Oct-Mar were normalized to produce a 12-month PE value representative of the

winter, The normal annual PE was divided by the winter PE to produce a moisture adjustment factor

(60%).

PE Equation

PE=:

12

115 [PIT-10] 109

where P is average monthly precipitation (inches) with 0.5 being the minimum value

T is average monthly temperature (degrees F) with 28,4 aF being the minimum value used in the

calculation.

Parameter rt tk ®A ^r Mav Jiut Jul Yu Sr. ® 1 Yea

40.5 -1 t7.6 53.7 58.6 63.7 53.3 50 50.2

® 5.$9 ®®® I.06 1.16 ® 50.76

The calculated 60% adjustment was reasonable when compared to other information: ORCAA regulations

specify reasonable and/or appropriate precautions shall be taken to prevent fugitive particulate material

from becoming airborne (RULE 8.3 (c) General Standards for Maximum Particulate Matter,

Emissions Inventory Improvement Program estimation method applies 50% control to PM nonattainment

areas.The Western Regional Air Partnership and AP 42 attribute 10% - 74% cont rol efficiency for

watering depending on schedule and operation

R Western Climatic Data Center. 1996-2008 Aserage Ion tilt Olympia Airport meteorological site.

9 Raid, Table 32:

33
Appendix F. Inventory Preparation Plan

'r<thle of Cott€:ents

Inventory Preparation Plan 34

1 Introduction 35

1.1 Cieogrephic Area 35

1.2 Temporal Resolution 36

2 Inventory Development 36

2.1 No npoint Sources ` 37

2.1.1 Residential Wood Combustion :..: 37

2.1.2 Road Dust 37

2.1.3 Construction Dust 38

2.2 Onroad Mobile Sources : 38

3 Spatial Allocation Methods : 39

4 Temporal Allocation Methods : A 40

4.1 Residential Wood Combustion :.;.,: , 40

4.2 (Inroad Mobile Sources : 40

4.3 Road Dust :..: 40

4,4 Construction Dust :..: 40

5 Quality Assurance and Quality Control s :..:; : 40

6 External Audits 40

7 Responsibility 40

3 Schedule :: : 40

34
Inventory Preparation and Quality Assurance Plan

Thurston County PM1 o Maintenance Area

f Introduction

A portion of Thurston County, Washington exceeded the newly adopted 24-hour PM 1 ,,standard of 150 ltg/m3 iu

1987 and was designated Group I by EPA for violating this standard. In 1990, the area was designated

nonattainment per the 1990 Amendments to the Clean Air Act. The area was reclassified to attainment in 2000

when EPA approved the first 10-year maintenance plan for Thurston County in December of 2000. The

maintenance plan for the second 10-year period was due before December 2010. Once approved by EPA, the

second ten year plan will fulfill the final maintenance planning requirement of the Clean Air Act. This Inventory

Preparation and Quality Assurance Plan (IP/QA Plan) is in support of the development of the required second 10-

year PM,o maintenance plan.

The Thurston County PM,p maintenance area (TCMA) includes the cities of Olympia, Lacey and Tumwater and

unincorporated areas within or between these cities' boundaries. Air quality is monitored at the College Street

monitoring station in Lacey. The area has been in compliance with the standard for decades. The design value for

2003-2005 was 42 .tg/m ' . Measured Federal Reference Method (FRM) PM,,, values were so low that the monitor

wus removed with EPA approval in 2006. Since then, only continuous, non-reference method monitoring has been

conducted in Lacey with a correlated nephelometer,

Ecology will prepare the maintenance plan in coordination with Olympic Region Clean Air Agency (ORCAA).

Because the area has been in compliance for many years and the risk to the community of exceeding the PM I o

standard is low, Thurston County qualifies for the Limited Maintenance Plan (LMP) approach, A LMP assumes

there is low risk of exceeding the standard and the demonstration of maintenance is presumed to be satisfied. A

LMP includes a base year (attainment) inventory, but does not require a projected year inventory. Ecology proposes

using existing information from Ecology 's 2005 triennial emissions inventory ' (2005 El) and the 2008 National

Emission Inventory (NEI) to create the inventory for the most significant emission sources.

The following sections describe the planned approach to the LMP El and the basis for selecting that approach.

Ecology is submitting this 1P/QA Plan for EPA approval.

- I.1 Geographic Area

The TCMA is located west of the Cascade Mountains at the southe r n end of Puget Sound. The College Street

monitoring site is at the Mountain View School in Lacey, WA at an elevation of 70 meters, (230 feet). Figure t

below shows the features surrounding the maintenance area and the location of the monitoring site.

Washington State Base Year 2005 County Inventories. Washington Slate Department of Ecolom Air Quality Program. Sally oneson. June

8, 2007

35
Figure i - Thurston County Maintenance Area

1.2 Temporal Resolution

Historical exceedances of the 24-hoar PiV[ Itt standard occurred primarily during cold days from October through

March. Therefore, the inventory will address average winter daily emissions in the maintenance area in addition to

annual emissions.

2 Inventory Development

Ecology and ORCAA will develop an emission inventory using readily available data. We will document the

estimation methods and gather information from the relevant inventory reports. We will begin with existing county

data and temporally and spatially allocate it to the TCMA. The emission inventory will include annual and winter

day emissions.

Initially, we proposed four emissions categories be included in this LMP. This was based on a review of emission

categories listed in the first maintenance plan, Table 2.1 shows the breakdown of MIN emissions for an average

winter day in 1995.

36
Table 2-1 - 1995 PM 11 , Average Winter Day Emissions

Emissions Categories Tons Per Winter Day Percent of Winter

Day Emissions

Road Dust 2,27 ?5..3'%

Vehicle E'haustand Tire Wear 0.57 6.4%

Construction Dust 0.5 5.6`%

Residential Wood Combustion (labeled Wood

Burning in 1995 plan) 5.45 60.8%

Open Burning

_

0.04 0.4%

Airplane Activity 0.07 0.8%

Point Sources O. l 1.1%

The most significant sources of PM 1 ,y in the TCMA were and continue to be Residential Wood Combustion (i.e..

Wood Burning) and Road Dust. Smaller contributions come from Vehicle Exhaust and Tire Wear and Construction

Dust. Other sources are deemed insignificant and will not be included in the inventory. In previous discussions,

EPA agreed that these Pour categories are all that need to be included in this LMP. Inventory values are available

from Ecology's 2005 El for Thurston County for most of these source categories ' . Since a 2005 El value is not

available for Construction Dust, Ecology and QRCAA would like to omit it from the inventory. While existing

2008 data from the NEI could be used, it is nor kind. This is discussed further below.

2.1 Noupoint Sources

Residential Wood Combustion. Road Dust and Construction Dust are nonpoint sources. These emissions are

typically estimated by multiplying an activity level, such as wood combusted or Vehicle Miles Traveled (VIvIT), by

an emission factor in mass per activity.

Emissions Activity level r Emission Factor

Estimation methods and data sources for these nonpoint sources are described below.

2.1.1 Residential Wood Combustion

Residential wood combustion (RWC)- emissions will be based on the 2005 El. RWC consists of home heating and

recreational use of woodstoves, fireplaces, fireplace inserts and central furnaces. The basis for the 2005 El include

the type of wood burning devices (certified (catalytic and noncatalytic) woodstoves, uncertified woodstoves and

fireplaces), the amount and. species of wood burned from each device and seasonal, daily and hourly usage rates.

Some of this information was obtained through surveys, such as WSU 's Wood Burning Stone Survey for Idaho,

Oregon and Washington State (2001). Emission factors were taken from AP-42, the 2002 NEI, and the PM size

distribution from the California Air Resources Board (GARB).

2.1.2 Road Dust

Road Dust for paved and unpaved roads will be based upon the 2005 El. Average Daily Vehicle Miles Traveled

(ADVIMIT) for Thurston County was estimated by Washington State Department of Transportation (WSDOT)

through use of the national Department of Transportation's Highway Performance Monitoring System (HPMS)'.

IJPMS includes a system of traffic counts collected over several urban and rural sampling areas. VMT on unpaved

- The categories are defined in the 2005 Emission Inventory Guidance For Implementation of On-me and Particulate Matter National.

Ambient Air Quality Standards (NAAQS) and Regional Haze Regulations.

3 2005 HPNIS Mileage and Daily Travel Summary. 1Yashimiton State Department ofTransporlalion. July 2000

37
roads was estimated using data from the County Road Administration Board (CRAB) and WSDOT, The Road

Dust equations in AP-42 were used to calculate emission factors'' ,

2.1.3 Construction Dust

If Construction Dust is included in the inventory, data from EPA's 2008 NEl would have to be used because neither

ORCAA nor Ecology has local data for this category for 2005. The 2008 El data includes construction dust in three

categories: industrial/Commercial/institutional, Residential Construction, and Road Construction.

• Industrial/Commercial/institutional construction dust is a function of the acreage disturbed for nonresidential construction. Regional variances in construction emissions are corrected using soil moisture

level and silt content. Values on this activity are taken from census reports such as Annual Value of

Construction Put in Place s and County Business Patterns° as well as the Bureau of Labor Statistics '.

• Residential Construction Dust emissions rely on information on housing gaits" and building permils nw to

estimate emissions from soil disturbed fi'om this activity.

• Road Construction emissions arc based on the amount of land disturber for road construction, These values

came from the Federal Highway Administration (FHWA)

Top-down inventories such as the NEI have inherent uncertainties because data is collected nationally and

aggregated. Based on these uncertainties and because of the small contribution of thi category to the total,

Ecology and ORC4.f would like to omit this category from the El. We request EPEE corrcurrence.

2.2 Onroad Mobile Sources

Oluroad mobile source emissions are those generate is operating vehicles on public roadways. Emissions from

tuel combustion and evaporation, and brake and tire v,eru a ill be estimated based on the 2005 EI. The activity

measure for onroad mobile sources is the number o[ mites. drivers, The units are typically given in ADVMT.

I kIT

ADVMT for Thurston County was estimated by WSDOT as duscribecl above in the Road Dust section.

Emission Factors - Tailpipe Emissions and Brake and Tire Wear

Onroad mobile source emissions were calculated with EPA's Mobile 6,2 model. Emission rates in grains per mile

were generated for unique combinations of month, vehicle type, pollutant and pollutant type (exhaust, evaporative,

brake wear, tire wear). MOBIL.E 6.2 uses a combination of default and local input data to estimate emission

thctors. Local data was used for the following input parameters: evaluation month (age of fleet), registration

distribution, temperature, humidity, and fuel parameters for Reid vapor pressure (RV P), fuel program, and diesel

sulfur content. The parameters are described in Section 3.3 of the 2005 El. The model parameters and data sources

are listed in Table 2-2 below.

Compilation of Air Pollutant Emission Factors, Volume Jr Stationary Point and Area Sources. AP42. Section 13.2.1 Paved ( 11; 06) and

Section 13.2.2 Unpaved ( 1 U06).-{Note that the methodology for calculating Road Dust for the maintenance plan was different. The

alternative method correlated relative humidity and entrained road dust using a WSDOT 2006 algorithm.)

lytta? ::, F L:yY::sslt ytmti__i _onn5. u^vY wessSS>ttrr^ti.l.l€ia1,1

6 [Isgi mwinveeensa4 ginissesonnt2g irks ltt.nl

h to wew,hl- os ilatiti Table B.mNR

a New Privately Owned Housing Units Shifted for 2008 ( Not seasonally adjusted), Itcl!)_ rvs2s t.cp,u, ; w>m conSUserttiu.l,txif

' Table tau, New Privately Owned Housing Units Authorized Unadjusted Units for Regions, Divisions, and States

ht.Inttssss-Ans4mStinetietits, i ^lli_LJ$o TabIsnI th2r1219. _1\.C

Annual Rousing traits Authorized by Building Permits C02007A. purchased front US Department of Census

" Type of Foundation in New One-Family I-louses Completed. h t a ;;cs;xv. tstann s genn;yn>5[; C;,' ,Ann!:_tiis':aliau;ld_a.. n

38
2-2: Mobile 6.2 Model Parameters and Data Sources

Parameter Data Source

Temporal allocation to month and day of week WSDOT

Reid vapor pressure Fuel surveys from Alliance of Automobile

Manufacturers and TRW/Northrop-Grumman

Diesel sulfur content Western Regional Air Partnership (WRAP)

Temperature and humidity Olympia airport meteorological site

Vehicle age distribution State Dept. of Licensing, State Office of the

Superintendent of Public Instruction, Federal

Transit Administration

3 . Spatial Allocation Methods

Spatial surrogates are used to approximate emissions inside the TCMA from county data. For sources without

specific coordinates, spatial surrogates are used to approximate both the location and magnitude of the emissions.

TCMA emissions are estimated as:

Ercni, = Ec0 ,,,r. * Surrogateresi a / Surrogatec0,,,,,,•

Where ETc^J. = emissions in the TCMA, Ec,,,,,,^„ = emissions in county,

SurrogateTC a i.^ = surrogate activity in the TCMA, and Surrogateco,,,, L} = surrogate activity in county.

The spatial surrogates and data. sources used are shown in Table 3-1 below.

Table 3-1: Spatial Surrogates

Sector and Category Spatial Surrogate Data Source

NONPOINT SOURCES

Construction Dust -

Industrial/Commercial/institutional,

Residential Construction Dust

Population 2010 Census

Construction Dust - Roads Road miles Thurston Regional Planning

Council

Residential Fuel - Wood Population 2U l0 Census

Road Dust Road VMT Thurston Regional Planning

Council

ONROAD MOBILE SOURCES

All Vehicles Road VMT Thurston Regional Planning

Council

39
4 Temporal Allocation Methods

Annual emissions data will be adjusted to tons per average winter day for the maintenance area for each source

category. Methods for each category are described below.

4.1 Residential Wood Combustion .

For residential wood combustion, seasonal activity fractions from the WSU survey for western Washington were

used ' to calculate emissions for a winter day.

4.2 Onroad Mobile Sources

WSDOT provided mouthly ADVMT adjustment factors based on 2005 traffic counts.' The factors were used to

calculate winter day VMT. The winter emission factors calculated with MOBILE 6.2 were multiplied by the winter

day VM.T to estimate emissions.

4.3 Road Dust

WSDOT provided monthly ADVMT adjustment factors based on 2005 traffic counts. ; The factors were used to

calculate winter day VMT on paved and unpaved roads. Winter emission factors were calculated assuming no

raint<tll, and therefore no moisture adjustment. The emission factors were multiplied by the winter clay VMT to

estimate emissions.

4.4 Construction Dust

Monthly and weekday activity adjustment factors for construction equipment from EPA's NONROAD model will

be used to allocate the 2008 NEI annual emissions to average winter day emissions, if included in the inventory. A

further adjustment will be made for average winter. acid moisture..

5 Quality Assurance and Quality Control

We are using existing data that has already been quality checked. ,Ecology uses the data quality objectives of

accuracy, completeness, comparability, and representativeness. Ecology and ORCAA staff will perform quality

assurance on the spatial and temporal allocation of emissionsftom the existing inventory. EPA has a process for

assuring the quality of data in the NEI, if Construction Dust values are included.

6 External Audits

The state is willing to he audited by EPA, and make changes to this inventory preparation and quality assurance

plan if warranted,

7 Responsibility

Since we are using available data, the inventory process will be simplified. Ecology will create the inventory with

assistance from ORCAA. Both agencies will participate in inventory review and quality assurance activities

outlined in this plan.

8 Schedule

The section below shows the schedule for document submittal to EPA Region 10, Ecology will submit a draft

inventory to EPA upon their request. We will submit the final inventory according to this Inventory Preparation

and Quality Assurance tlP/QA) Plan.

12 2005 El, Table 3-5S, page 63

r' Email from Guoreng Liu, Washington State Department of Transportation to SallyOttersorr, Washington State Department

of Ecology. Transmitting spreadsheets with monthly, day-or-week, and hourly adjustment factors. monthf•.ie_ail..xls,

dowfac all.xls, hourfac all.xls. Sept. 5, 2006.

is Ibid.
Schedule

• SIP Development Plan Provided to EPA, June 16, 2011

• Inventory Preparation Plan (IPP) Provided to EPA October 2011

• Plan Development and Supporting Technical Work July-December 201 l

• Draft SIP to EPA November-December 2011

• Present Draft SIP to ORCAA board January-March 2012

• SIP to EPA January-March 2012

• EPA Approval September 2012

41
Appendix G. Olympic Region Clean Air Agency Regulations

t

Regulation 6, Rule 6.2:6 Oi.3td9 p3_13ui_ni .p p itiorts)' ffi ~t

Regulation 8, Rule 8.1, Wood Heating (pq::bons,)

RULE 6,2 OUTDOOR BURNING

RuIc 6 2 _ rrsi_der)tlul ,or. land Llearingl3^€rn. iG) _is. allow Ld. in_tin. ioollowing ciltes rrx ;:_cn I (....

Rule 6.2.6 Curtailment

(a) No outdoor fire shall be ignited in a geographical area where h bairn ban has been declared.

(b) The person responsible for an outdoor fire must extinguish the fire when a burn ban is declared,

(c) Three (3) hours after a burn ban is declared smoke visible from all types of outdoor burning, except land

clearing burning, will constitute prima facie evidence of unlawful outdoor burning.

(d) Eight (8) hours after a burn ban is declared smoke visible from land clearing burning will constitute prima

facie evidence of unlawful outdoor bunting..

Rule 6,2.7 Recreational I3rrr n?rr

Thefollowinu bum practices shall be used thrrecreationalburning where allowed,

(a) Maximutar pile size is three (3) feet indiametet and two (2) feet hi,aJL WA(: 173-425-060j

( ,}. t^nly dry, tic )s neci fareyv uci,or el^clrv C irid1 enough ckin_pat^et necessary tu_5t art_3. lir rrw.t he, burned

^c ...4o:ccl. e rtrc^la^l_tires are_tllowccj }vtthin t, ate Isnl>rts of Laacey ©Iytnpia tad 1 umu to and

iic>_inc orpornted uc a ui 117tttslon (ouniy lythin or bc,twcc n the ttutrll^il^ 3(_L?c^ and ii_ics cif then .,^ilies.

C:h;nccai one, or natural gas ma lie used without a pencil..

RULE 8.1 WOOD HEATING

The provisions of this ruleapply to solid fuel burning devices in all areas within the jurisdiction of Olympic

Region Clean Air Agency (ORCAA). .

Rule 8.1.1 Definitions

"Adequate Source of Beat" means a furnace or heating system, connected or disconnected from its energy

source, designed with the ability to maintain seventy degrees Fahrenheit (70°F) at a point three (3) feet above

the floor in all normally inhabited areas of a dwelling. Garages are specifically excluded.

"Certified" means that a woodstove meets emission performance standards when tested by an accredited

independent laboratory and labeled according to procedures specified by EPA in 40 CPR Part 60 Subpart

AAA-Standards of Performance for Residential Wood Heaters as amended through July I, 1990.

"Cook Stove" means an appliance designed with the primary function of cooking food and containing an

integrally built-in oven, with an internal- temperature indicator and oven rack, around which the fire is vented,

as well as a shaker grate ash pan, and an ash cleanout below the firebox. Any device with a fan or heat

channels used to dissipate heat into the room shall not be considered a cook stove.

Grays

Harbor

Cariaborg Aberdeen

Clellam Bay Hocluiam

Forks

Joyce

Port Angeles

Sekiu

': Sequirn

Clallam

Port ' Allyn

Townsend Belfair

Irondale Shelton

Port Hadlock

au_

Jefferson Mason Pacific l

Ilwaaco Bucodra

Long Beach Grand

Raymond Mound

Seaview Lacey

South Bend Olympia

Rainier

Tenino

Turnwater

Ye]m

Thurston

Formatted: Font: 11.5 pt, Bold, Italic

42
"Fireplace" means a permanently installed masonry fireplace; or a factory-built metal solid fuel burning

device designed to be used with an open combustion chamber and without features to control the air to fuel

ratio.

"First Stage of Impaired Air Quality" means the same as Stage I burn ban and is declared when

meteorological conditions are predicted to cause fine particulate levels to exceed 35 micrograms per cubic

meter measured on a 24 hour average, within 48 hours,

"Second Stage of Impaired Air Quality" means the same as Stage 2 burn ban and is declared when a first

stage of impaired air quality has been in force and has not been sufficient to reduce the increasing tine

particulate pollution trend (RCW 70.94.473). A second stage burn ban may be called without calling a first

stage burn ban only when all of the following occur (RCW 70.94.473(c)(ii)):

(a) Fine particulate levels have reached or exceeded 25 micrograms per cubic meter, measured on a 24 how

average:

(b) Meteorological conditions have caused tine particulate levels to rise rapidly;

(c) Meteorological conditions are predicted to cause fine particulate levels to exceed the 35 micrograms per

cubic meter, measured on a 24 hour average, within 24 hours; and,

(d) Meteorological conditions arc highly likely to prevent sufficient dispersion of fine particulate.

"lNonnffected Pellet Stove" means that a pellet stove has an air-to-fuel ratio equal to or greater than 35,0

when tested by an accredited laboratory in accordance with methods and procedures specified by the EPA in

40 CFR Part 60 Appendix A, Reference Method 28A-Measurment of Air to Fuel Ratio and minimum

achievable burn rates for wood fired appliances as amended through July 1, 1990.

"Salt Laden Wood" means any species of wood that has been soaked in salt water,

"Seasoned Wood" means clean, untreated wood of any species that has been sufficiently dried so as to

contain twenty percent (20%) or less moisture by weight.

"Solid Fuel Burning Device" means a device that burns seasoned wood, coal, or any other nongaseous or

nonliquid fuels except those prohibited by Rule 8.1.3. This also includes devices used for aesthetic or a space

heating purpose, which has a heat input less than one milhdn British thermal units per hour. A cook stove is

specifically excluded from this definition.

"Treated Wood" mean wood of any species that has been chemically impregnated, painted, or similarly

modified to improve structural qualities or resistance to weathering or deterioration.

"Wooclstove" means an enclosed solid fuel burning device capable of and intended for space heating and/or

domestic water beating.

Rule 8.1.2 General Emission Starrtlru•ds

(a? Ne-g rson-sl&ll + ear tllew ssa emission from a scrod fuel burning clevice-t/sa e

with-the -use: imit.enjeysrte t...ed-irsetpeet rrwrrk ieeu

(b) No person shall cause or allow emission of a smoke plume from any solid fuel burning device to exceed an

average of twenty percent (20%) opacity as determined by EPA Method 9. The provision of this requirement

shall not apply during the starting of a new fire for a period not to exceed 20 minutes in any 4 hour period.

(c) Smoke visible from a chimney, flue, or exhaust duct, in excess of the opacity standard shall constitute

prima facie evidence of unlawful operation of an applicable solid fuel burning device. This presumption may

be refuted by demonstration that the smoke was not caused by an applicable solid fuel burning device,

Rule 8.1.3 Prohibited Fuel Topes

A person shall not cause or allow any of the following materials to be burned in a solid fuel burning device:

(a) Garbage;

(b) Treated wood;

(c) Plastic products;

(d) Rubber products;

(e) Animals;

Comment [lahm3): Needs discussion

43
(t) Asphalt products;

(g) Petroleum products;

(h) Paints and chemicals;

(i) Salt laden wood; or

(j) Any substance that normally emits dense smoke or obnoxious odors.

Rude 8.1.4 Curtailment

(a) Whenever the Agency has declared a Stage 1 burn ban for a geographic area, a person within that

geographic area with an adequate source of heat other than a solid fuel burning device shall not operate any

solid fuel burning device, unless the solid fuel burning device is one of the following:

(l) Certified; or

(2) A nonaffected pellet stove.

(b) Whenever the Agency has declared a Stage 2 bum ban for a geographic area, a person within that

geographical area with an adequate source of heat other than a solid fuel burning device shall not operate any

solid fuel burning device.

(c) The affected geographic area of a declared Impaired Air Quality shall be determined by the Executive

Director or their designee,

(d) A person responsible for an applicable solid thcl burning device already in ,periation at the time Impaired

Air Quality is declared shall withhold new solid fuel for the duration of the impaired Air Quality. Smoke

visible from a chimney, flue, or exhaust duct after three hours has elapsed from the deslaration of the Impaired

Air Quality shall constitute prima facie evidence of unlawful operation of an applicable solid fuel burning

device. This presumption may be refuted by demonstration that the smoke was not caused by a solid fuel

burning device.

(e) For the sale purpose of a contingency measure to meet the requirements of Section 172(0(9) of the

Federal Clean Air Act, the use of solid fuel burning devices, except fireplaces as defined in RCW

70.94.453(3), woodstoves meeting the standards set forth in RCW 70,94.457 or pellet stoves either certified or

issued an exemption by the EPA in accordance with Title 40, Part 60 of the Code of Federal Regulations will

be prohibited if the EPA, in constrltation with Ecology and the Agency, makes written findings that:

(I) The area has failed to make reasonablel'u•ther progress or attain or maintain a national ambient air quality

standard; and,

(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 attahs or maintain a national ambient air quality standard.

(3) A prohibition issued under 8. t.4(0 shall not apply to a person that does not have an adequate source of

heat without burning wood.

(4) The area is to consist of all areas within the city limits of Lacey, Olympia, and Tumwater and

unincorporated areas of Thurston County lying within or between the municipal boundaries.

Rule 8.1.5 Exemptions

Written exemptions granted by the Agency shall be valid for one (I) year from date of issue. Exemptions may

be canceled at any time if the original request is found to be incorrect, inaccurate or fraudulent, Exemptions

shall apply only to the use of solid fuel burning device during an Impaired Air Quality and not to the other

rules of this regulation or other applicable regulations.

(a) Emergency exemption. In an emergency situation the Agency may issue a written solid fuel burning device

emergency exemption. An emergency situation shall include, but is not limited to, a situation where a person

demonstrates that their heating system, other than a solid fuel heating device, is inoperable for reasons other

than their own actions or a situation where the heating system has been involuntarily disconnected by a utility

company or other fuel supplier.

(h) Inadequate heat source. Written exemptions may be issued by the Agency if a person can demonst rate that:

(1) The structure was originally designed with a solid fuel burning device as the source of heat; or

44
(2) The existing heat source, fueled with other than solid fuel, will not provide adequate heat,

Rule 8 .1.6 Penalties

A person in violation of tins Rule 8.1 may be subject to the provisions of Rule 2.5.

Rule 8. 1.7 Sale and Installation of Uncertified Woodstaves

It shall be unlawful to install, sell, offer for sale, advertise for sale, or otherwise transfer an uncertified solid

fuel burning device unless the device has been rendered permanently inoperable as a combustion device.

Rule 8.1.8 Disposal of'Uncertifiied Woodstoves

At such time as an uncertified solid fuel burning device is to be permanently removed from its location it shall

be rendered inoperable as a solid fuel burning device. A removed uncertified solid fuel burning device shall

not be sold, bartered, traded, or given away for a purpose other than recycling of the materials to form

something other than an uncertified solid fuel burning device.

45
Appendix H. Washington State Regulation - Solid Fuel Burning Devices

1,.,aat 1. txlate: 9.16J07,

do hot accept.

_T

i Comment [lahm4j: Leave strikeout changes,

_J

c:toter J.73-433 ! `At: S(31..11) FUEL BURNING DEVICE STANDARDS

Redline strikeout version,_s€ lected sections

e--{ate t cha. fl-in-Washing-ton-Register:

: < aff eti c°: 2 -16,4'"-nP4-citee ai 1!I

1.73-433-030 Definitions

The definitions of terms contained in chapter 173-400 WAC <u c Incorporated by reference, Unless a

different meaning is clearly required by context, the following words and phrases as used in this chapter,

shall have the following meanings:

(1) "Adequate source of heat" means the ability to maintain seventy degrees Fahrenheit at a point three

feet above the floor in all normally inhabited areas of a dwel ling.

(2) "Certified" means that a woodstove Meets emission performance standards when tested by an

accredited independent laboratory according to procedures ,,

. h

(3) "Coal-only beater" means an enclosed, coal barlringapplianeeeapablc of and intended for

residential space heating, domestic water heating, or indoor cooking, which has all of the following

characteristics:

(a) An opening for emptying ash which is located near the bottom or the side of the appliance;

(b) A system which admits air primarily up and through the fuel bed:

(c) A grate•orother similar device for shaking or disturbing the fuel bed or power driven

mechanical stoker; and

(d) The model is listed by a nationally recognized safety testing laboratory for use of coal only,

except for coal igaitiol: :n irpeses.

1 ' "EPA" means United States Environmental Protection Agency.

Comment [Iahm5J: Not being submitted, na

changes sirree last approval, omit

46
|*, "New Wv*dvm,e`means u*ooduovothat has not been sold at retail, bargained, exchanged, or

given away for the first time by the manufacturer, the manufacturer's dealer or agency, or a retailer, and

has not been so used as to become what is ouarmuulyknown as "second hand- within the ordinary

meaning of that term.

" Ketohr" means any person engaged in the sale of solid fuel burning devices directly to the

public. A contractor who sells dwellings with solid fuel burning devices installed or a mail order outlet

which sells solid fuel burning devices directly to the public is considered to be usolid fuel burning device

retailer.

"Seasoned wood" means wood of any species that has been sufficiently dried so as to contain

twenty percent or less moisture by weight.

1,"Solid the! burning device" (same as solid fuel heating device) means a device that burns wood,

ow, or any other nongaseous mmmUquki fuels, and includes any device burning any solid fuel except

those prohibited by 9V AC 173-433-120. This also includes devices used for aesthetic or space-heating

purposes in a private residence or commercial establishment, which has otwat input less than one million

British thermal units per hour.

:"Treated wood" means wood of any species that has been chemically impregnated, painted, or

similarly modified to prevent weathering deterioration i.

"wvodsm,e" (same as "wood heater") moans an enclosed solid fuel burning device capable of

and intended for residential space heating and domestic water heating that meets , ;

:-

^/-

^'
CFR 60 Subpart AAA - Standards of Pertormance for Residential Wood Heaters

An air-to-fuel ratio in the combustion chamber averaging less than 35.0, as

determined by EPA Reference Method 28A;

A useable firebox volume of less than twenty cubic feet;

A minimum burn rate less than 5 ,gJhr as determined by EPA Reference Method

28;

A maximum weight of 800 kg, excluding fixtures and devices that are normally

sold separately, such as flue pipe, chimney; and masiruy components not integral to the

appliance.

Any combination ot'parts, typically consisting of but not limited tot Doors, legs, flue pipe collars,

brackets, bolts and other hardware, when manufttictured for the purpose of being assembled, with or

without additional owner supplied parts, into a woodstove, is considered a woodstove.

State effectire: 10/18/90; EPA effective: 1/15/93

WAC 173-433-100 Emission Performance Standards

(1) Wooclstove sales.

473-433-10Et t i,G perfe r°m n<:e-sts it4t^ ti k 4- 'oodsteves.

person shall not advertise to sell, offer to sell, sell, bargain, exchange, or give away a new woodstove in

Washington unless it has been tested to determine its emission performance and heating efficiency and

certified and labeled in accordance with procedures and criteria specified:

(?3 :Mel . t:i t*w:.

. vfle?cd t rr ,.-"_1 _t fla_rfgt s:tt#: 1.`:.ab,134 *,

I EQ-h+ -- strati e-Rules, Chapr3'1- 4i aen 21--Wood:st

ei#,i.hc a.Ejor; Fl ittyki.. !? .' tt g . _d- ^ 1 _z acl-qpt i. 1t fry ft Fl ory til;e;tt ()logy;. f?t:

{ii}. t.t}>_ . _R . in"40 CFR 60 Subpart AAA - Standards of Performance for Residential

Wood Heaters' . tE cl_€_ l rtj,:<3.2 -. ` rga:lo a m-r ...rlk - rr.3_. n_ #.1 _3t ?

. _l cltl,i_r_et jc rte# rrl Fte.» c l±ft# zj,»ijj _ I. Ei s._i rWgsbitrait aftci°1. -W90;_a

48
SE:^sttE+3a:^cry,sri-^allctll-ttctt act^r^+'tt^c gct,^ld, cat^^r. tcs y^^l; Mwll, l^^trμ5t.);tn ext^lr lta^^,_E^t^tta^ t^^^^::sE::rt.^"!^`

oof1t,

-ia-Wasl'+ittgtan-trrr4 ;;-at hasb tt t-te-eIeEcrrrtinc its eirt r-perf rrnanee and

he tiaf eta iota v_verti fic.E1, rfaLej {eke 1 1 ter ak .t^t4la t} tt tt i i nd 3rot.edrn s s cctt I- by

fii1 „[.€ !eta t} 4t F>d4 art h i t ^4 _ t,ammd ti-tihf> Perlin-inat t.e . 6i 6 e.,x<4enthil- Woods}-.kklttrw._

(lat,A44ehr'tsarv 26, _-. L. atr ti}e at ec^ 4a

t-2-1-L t Mien:i. The-le It oin solk4-r-u l burn inv devices areexeertpl4 tn-td regatrerttet :+-efOti

(a-)-Sell rue! btt44 -tit-an-or-before I98S,

-Any-ctrl-i l-Metal-latFr-l og--d e oxen-vied-Hinder..Or e-Ruler Chapter-340;

.Division e1n6eatic r"-dated- aw l9^t S-4-lb nppiopfiatc la-beknt-or

'',YT .tea t)veof = s rr^ t (;Y}lu T^:L1Trt i l^ d ;4>r i i;e fJ F 4 :

iei_-tNny. at}:tett _tl inAey_tu txglIptec. tr}<ki- ''... I ,G . lk+N #-AA4\--5tfttA,* c;s_ct

ix erCalnatt ou-tit-i Resklenti0-4ogal € e-&t tsl- at t t^lcci kr<jfrQ#r, {Llty 13_7E9_02_ t: tjIar61).53

Fi r tt tea 3 c= ak, } r

ter:

;li r wt tt rE,aEt. ort r+a eL 13 far i ? j t}l rte; "Et, y_t)-tc ;t:oc}.

1 ,1en'ts>ta_stta t -ii tilt-s§+n r taew Ffaa aYta .cie _ta

tsecordaa+ce tivi 1--cfiteria aB4-preeedures no k rrnt cite than those io cler,.1O FR-6O Sul pee

\;r\:-; ttt)ac}Gu.d.-u:t::P ri.w. n.. tenr._Res+cd d- }€^lt ' ati aF ttci 31 t4ar fu kt.<tud ^ u ;

subje-ct-tie- to-}c3 l t -bons

I_r 411cttt r,- i ^l e l -ell- .1+4 r t1l tafc pp{iraFi Rai,... auraqtlim-Irtl9i-bA

c . 'toE FI't} cati011 t.:iti+t+^,^;

^3 i.a tat ie l t'rt littta++ttt#esiceslia-ld-be-e,rantic( )rtnv al-e test

Milt, teat-E}eta t= ttths .,oJibe , h__ ^t s: _c cc nce* l ion pl.r trc :?

grFt4v t , 1t.7f f Ett+ro -lit ee- 9 ("I I ql_ t it:b A A;-. Si-art ku €k ,. el I n letece; tcs+ }.e..atlent 4

weed-I tiers" a aznded4hnnuekJttlv-l-, 198-

f,ki-j =€ wseai ttati--rtt-ols- r fist ct_a e-ill ndl.. l> Eiji 1't+a a?tl ly t4tc pEC rd r+af+cte €de4ir --4an.La+ttj

aeeirk-at ie n-s-t+at--wer°eto milted. tested anti ri s tssred fctr-eerr3tat ttic^trb

-,_ ___ _on per(r r+tlare +ndiarck -i lt-attthorityshall not adopt or crIfulce-em-issiart

^t:^uE^EYtttra^;W^Wa^€anei,itfl g-#^iWW^er4^c^sc^EJat^t±+^ta-Eie^t+^=e^t}^Et^ far^ft^-sttlix^e:at t3 .tat^ t}3e ^Lzatc- e^ta;^ ^d:ar3^}=t^E}:

{-4-}-Gtrracs'en-peFfera+aan e standards fe -eiti tis:atiorl,

{-a-1-A--ne-iiiiiiti-m-aandist -aclot-i-sed-fo -sale,reffered-foe-sale, or :,+sltl aid \Vasltin

?+ra#i-er July 1.

Eari+ttL t F) t aft t rrMic:l sI{a1 se c;c-cEl-tlie-v. .€ rtc} the Ja tALI 4 Jt4atter4„1-rt*lf

R .uen 40 ? l d } 53t t__?rrinu eIi z4s .l tl :£ l a ty ._s^} _ Dili ore 21--- L'4-tRyl,tcwt'

r ..

fh)-A ew vi'hedstc;^ i ate erti:,cd Far s )r --saki in-Was}+i-rrpton after Jul}

l^ ,a 1^ ^ tca ^ttr.l ' ^i# it lclba141a11 ,,, ° e-c-4' tee stun cJ,fri .f€^r. >rt+efrha_t rtrJa ar

49
f€ll" L 1998

fib L,fib?")irk Kofieur fi)t§-:

{tt).G tat ^ ttty a ctr.kir€fi_Egg-be 4ctt iir.aiiant4tE f:t3€i)4-) 34 this- sec'tioll-sa_41. 4 E;+

l befitfrer;+ri r cf w-kf " : to ci aaE t Erv ^fir#^^: C:11 ^ € r _ 4} iii ^ iait^l 1

3.-e1c^ElHFi}es}t+isr"-clzEtee#: Ic>v€t^^

?7_CV e a tl r _ €vies„s-regtlirccl_tui7be-I-afa€1 -#nliataa>x-to-s-1 .

(1. (a){#+) c* b}of thsw..seiWe izr^l, T e-#o tr3 ectu and by rim 4 P ^ _u dez :_40 (ER fi¢). 5tt >at

AAA--.StanOrds ofPP erlbrmane -!' \eed-H#eatenin-dtcdt -hitizary''6, I :

}^ a#^e^:.atd^e^r^r^^i^.,_'^rrf.arE^tx:^^a^^t, c^ettl;^a^;^^t_r^c•trait^r^ftl^#}-rraat , ^ltea=t^lfke^c^ie:_i3€rip3^tralslr-r^t^ts^vra#^E^

tat• • : 1-abetq3tewed by the EPA or-f4 --t,)Eq

.L. `AY-e d,8(ly .:4-Agr_s_akiti.D _ --t tfFLacat4iTA' c s lff. eiet a ic_ l l l t±eE EC>m tt FeE{t9c r .ta t^ i Eck f ra

€ ul Er4 04at , (era fi E ta3^uf m, :eyed &ve ter t#^a frwse of

c-ES>a : #.iit kr E >zitr}r^ r^:Ea^ tt f 5af^n ._4st6^ r_

E.9}A1ttaa1ttry:te;t4ft.tkotr^clui^e -A;lVeeF H,. e t.te. k^txrn....taiet .fie- t-e e.Wfa.i a g

-<?^-.1^^^afar^a^_ac^^ai^ ^^t^lra^^# bt ;;a^k^3^t to arzt_a^kera^?t+^c i^::^kiaa^,f>r^x-^f^^re t^3_t.la^t-c.^,tu^rE^^;i, ,41 ..1ay

+ s f`1^. -Etnav a ^ ^:n ^y t irk ftea xive-car vdi* -m lye--e lj-L.' ^#t tit tr

_i_#3 )#IGxQ13t30.'!,.'. I- k f^rei#7tbl o.- -mk ,_ thL*'.rf;9^i4 Iii . #'}Ld3 31FEit?'L ei I4A. -hzE ^ ! ekiitct^I55U#j c1--I J t#1ih-^'.-PA t4".FP9^k ;

# Ei +eeI If-t to t } t e - - r r - a Lm - l ittali 1 }2 %e _`1-titferrafttic :c>r me czl !e i-Ht

#tO ti tsk _4t-tate . rcpt cluEEt ^.i ? c by_ oleg^, rt.sli01 . h t#-ic-ft 3 n,-ibttLs oft e-naaxu;#acttaiu4o

uboi i, the de it.e I s lktp_ cc #tt0d ,tin lttbc-k ztc t aF ._tiHI lt.u'fw > t 1Ogy Matt -f.tEIO t*5,t .f),tg ^.. ,If ti

;salt l e^yttt a# iit to ho-e .f t',ui-retl b t-;:- + O: ,hin- p.hzeertc gtton n trc t^ si_c1_-1_^ r

ter#af4^at^, n f^>s. peiioT not to L t, # ^t y^3za s a la, Le rt^et4 Sy.e ekt ,k c,3 tit,. #ie t: ,.ttn.g g-eood

-Erttefi -eerfi-fiet.6on m av l,s zekaew

TZCt#indc^ls.actpt cj_by_t}tc t a....5tate;s_ r.yirniiinc.nt_i1_[?rcitct:.tictitltgg,ncy:.. )tE ec#.ticnt_tc ^kLh_cltttc,:

meth io gv-adopted by-Me-1,1Med-States-Fawi pfin>rkekal-Pwtf-N:,f-ion Agency slkbsacliftsni-fe-see dote:

sff
:.: a'ISitatr +v- AnTh ri ty--€ -h- a r 7-0:9- 93 01- 105 (Ordcr-94-

55),1173 433 100, filed 23 ,93;-e€1i; 'rv 3 -. St€at t p r tat ' €'' 0 -i (i(r

(Order-. 90-5 F),f-d 7 43 --00,-Iil-ed 3420191: effei=ti-a 20,9..k, Statutots-:x uthertty:- ltd-W' 711.94;3 3 190-

19 062 (Order-90-4-O-)-k-' 173 133 100, filed 9117490, efifi O. Sta rt -Authority: Chapters

70:94 -andf-3:2-1: -RC' - -02 €35 -(Or r-r fi- --17:3-- 33-NI,41l 3 89,-3; -0-I--0-;.'% Orden 47 11 k•

....1._x;3. 433-1-011; 134 I

....12.A IC7ix& P:}

173433.-110 Opacity Standards

(1) Ph ;e--1- eii -1agel-A-lessor-^:ha l1-net-cause o l1€t^r• emie don of a timolaa plume:hem ai l-id

tuc*l bwa^ -qk' c -to axCeed-W► n r erns e-al turt^ perch#at;-opn*t s 1:31 son oti tnii gtnc:s +t sas ene

Pilik§e'),opocit -l_ a k-: ?t i Itt4 !.. ,1:. I'm) , 1mu 5c^n.- ti13 'EA lu e i}^ tll^ty.- lni. sion_uf. q.51 pl:c

plane forum €n' solid fuel burningdevice to exceed an aiseraroe id twenty percent opacity for six

cc^nsc cutiy.c, tllinut4 in ili oiuhouij t i1d..

{ 3 (-?_ Siate-^vicJe racite standard. An,authority shall not adopt or enforce an opacity level f'or nlicl_iiiu!

burntti cl^. ces_tltat is, more sttineent tl>ran t1 state-wide tandard.

f=1-))_(;r1 Test method arid procedures. EPA Meths ds_nod l r cc ur is sp citieci b^_the EP_1 in "40 C'_C',1 _6tl

A puncli, x ,1 ac fc rc mcc mcthotl) „ isflai M-girlinatron of tlhc Op icity of l irii:5ions_Imm St- ztionU'

Sources as amended through July 1. 1990,shallbe used to determine compliance with subsections (1) and

(5) (') Enforcement. Smoke visible from a chimnevv,_tlu ol_exhatust duct in excess of the opacity

tandart3 , dii<ill cc?rrslit€114-prima 1 uic-cd.3dcn)cc_i>! runirm^^iial l- I^in_nine

device. This presumption .may be refuted by demonstration thatthesmoke was not cpused by an

<1p lit,tllrl snlicl l burniLm._[.e. itcy,..The .lmri>l,•iytons of_th it lat-,}jail

(a) Be enforceable on a complaint basis.

(h) Not apply during the starting oft new.fire for a period not to exceed twenty minutes in any

ti)u,i. - h ca 1rr. bx_ri 1x1..

t L_chi.t €tic3t .-;^nE . ersj^n o). retailer 7a:cas icling information on the operation of solidfuel tburnirn r devi es,

9u,ch i^ brtx luiit. a-ctc=mo€m,tr)tacma€^__aritl priblj^_,cd.acaticljm proranmaz h_c)ulcl tnc hide infottn ttton th mt

opacity levels of ten_percent or less are attainable ti?rough_proper operation.

51
10/l 8/90; _E_D _active: 1/1'5/93

5

(2) Treated woo(k

Plastic and plastic ILrgdWs,

WAC 11734L3-1_40 . Quality Criltria.

Impaired air..a.rality shall be determined bN: eco[Qgv or an aulb_Qfily in accordance with the folloiAing

Ltriteria:

micrograms per cubic meter; or

__thl^arbon niono_,cide at or abo \,eanAttibient level of eight contaminant per mjlgn parts of()ir

(2rSecond stage impaired airquality" -the second stage indicates thewsence of particulate rntperteo

cubic rneteE,

52
{>> ....... ...... y..i .. . t:!iug

device; i-111pecified under WA(' 173-43-150(6) a single stage of imjkred tir quality will apply within

li iri.clicotc'thc

PAKm.cgst

JaiParficulleniter tem microiKsindnts11sisulitsmeser JPM 1. tit (..? .... up_

ni new micrograms per cubic meter: or

_112SAE12IIEups2sl 12 .ts.2ylt. g.n ..arsticsitcy. i.s.1f.4 g.hS..p.urbLobiossfamjsisint,ppits,

.... rhs&,

_(a PgLiculate matLeLtt2pmicrons and smaller in diameter (PM i,r

(0 Procedures specified by the EPA in "40 C.1 .R. 50, APPENDIX J- REFERENCE METHOD 10R

N D : 0N QUM ... f%to

amended 1990A111 he uspsilputits1r,rq'ferens; 4inl2jel)LEMmt'AtwcTl:t-qur4our

average.

fiLtsiAsLambiemi PM pomeasurement method rpm be utilised to evaluate air quality

imm -

illnciltif i ...

the s uric _location

and in parallel to the reference method. and must be related to the reference method by a mathematical

-

Al?). (-..Al.AP film ..g111:11Q1

_.C LLILAUEN21 .. .

DETERIvIlN-ATION OF CARBON MONOXIDE IN THE ATMOSPHERE (NON-DISPURSIVE

1NE1..1RED 191Q,,

-

j)_ I'AuacoiSpys used to measure eMkAr e4 la tiuti_c f_zi jislimpairuesit

.. .....

areas,

wAc173433450 Cu rita ilinent

t-l-)A-pers.off-ii-t-a-Fesidenee-orprate-_our ee-A-1E.a.t-t3th INti-t-he

Lit)-AY-11Lt.y.7s..'.gpl.qwy-hiit &el B.Pe.,E.Is a 1, -.mm h

el ttipt ,

.e*eep-t-when-t-h-e-afi-d-fucl-bitfil-i-ng ea-c • ° ifiedt 1.33 1410.

IH.b

geogrvhical are,a t_sIgn-it.aili-La residence or commercial establishment within that t?,tNgtApIlical area with

gain

device.unless thesolidfuelttmillgdevice Lt2pe ofthe folio w in tysi

53
f u w

1J_s_:nc^r^fll:Fetc(i. }allc_;t_sti^4 e;-.i3_

^L7;)_ _wctnclst9l-.e_ urtitii ci ancl_11bdu. ij12 t11e LP ._uildct 40 , t,F.IL(A)_SiOpWlIt .r..... Sta__ci ltds_oti .gifg.rn7 ne_ tnr_R.e ac'c{Gtrctl_W.god 1I 4 (ttr^_l.y a ;, 1 ., lt) )t) or

^^) l.rrczgclbta)yC, i)lc.r.. nz*the 'f re r li. _T3c firfimt nt of I.:nvirc>rtrileral?. I ._C^ulslit;y_ 1'kt :^e 2' cm

standards contained in Subsee1ioiis_(2) aarad (3) of Section 340-21-115, and certified in actoriianeewith

"(Jregon ll.clrnuustia _Ru_1c_^ Chaptcl U.,..C}it;ision 21 _ SJczc^cistt^vc ,_ d1t)tt noon ber

( . Whencyer_ecc^lc)^;v cai..zin , tautliE3rity hsis_clecl,.llecl the cc^k^ci.t.titg' o t_cc

geographical area a _person in a residence or commercial establishment rvitiiinthat geographical area with

an adequate source of heat other than a si)Ijd fuel burning device shall not operate aany solid fuel burning

device.

{3_)_i hDJevei v(czln y has_clnclW...._a7€l. air„pt311aatta^r_ i )sI ilt__ilevCt abovc t A.p. et an iala

r^sitic-ncc_o^ urnraricac^al etit.iblt.lirc.nt wvitlundiet gep. ap n^_Jl area ° umec. of heat

other than asolidfuelburning device shall not operate anv_solid fuelburning device.

(4)'The_following matrix graphici y^ illustrates the applicabili u of different types ofsplid fuel burning

clevat c^_ro_thc lstnvit ionLa_. ub.ccrsf s_ .) tlu_nra lr_ 3) qt tl is section

Alert,

V rfirig,

im ot, _t2r ?t:'_t`

First

,St,=Lu

Second

l:ar,,t;

----

^'€3rC ^l^t

0?'

I;.t1^CF'(; 11f 'mm

j Pellet tote, .

..

{7IG

_

No

I (:)1C NO

1 Pia Certifies.

Woodstove 0K NQ OK NO

DEQ Phase 2 OK NQ OK NQ

[:PA_EYeltrpt(;

Device

NO N{) C)K NO

All Other Devices

NO O

NOTES: "OK" indicates that the deice rnav be operated

"V©" inclic<att;s tlr<aaC_tlte .tluvic. ;_rl ;?1r... notbef>per ted

(51 On or after July 1. 1995, an authority ma;_ .atiplaibit use of solid fuel Yarning devices within specific

geogt'aphica.I areas:

t tu)_Tlle ti)llow'irlg..fitlctors_slh... be consider-ncl;n., tlJe_exerc;ise at: tflis lii)aitmation_

(i) The contribution or solid fuel devices that do not meet the standards set forth in "40 C".LR. 60

54
5ubl7art..__16. ...51_4r)dar t.gF;rriKjar,rde„ io,t'..Rctird.r.t..l l oixl_11s.<rtGrS. '„ .rti .........h.i.c^uS;h-July'._l.-

I990, to nonittaintrrent of national anrbienr air quality standards

(.i,i_ _l:l.cspuJ.tilatit.n_cl ^i itv,_ot:the. rpt.Ii al.l_ _ ,t,)zrtll^l.ic<tl

--

<}restLartd

(iii}"T ire ,}xil,lic_ttttzlitt ll: ts.c.,Ft.l..e; u,c csi:. olul I'il I c9c^ic4 tishl t ..,c1,>nESt. Triu t. ttiest_antl.....- ut1.}?l.th

in "40 C.F.R. G(} Sub dart AAA - Standards of Performance for Residential Wood Heaters" as amended

tl.;.s.u l.ltal.y._L. 19 .Q

tit) The follow-inct solid fuel devices are exempted from this limitation:

( F t1 Fireplaces:

f?iLW 1.;.i c:.ls.l_. t;l} _I .... ur -'., f} 'F':f .:.,6E?_ uh _ia.A .-°.. tu^ci^rECl -c #'

Performance for Residential Wood Heaters" as amended throuch July 1990: or

-_._ Nome.. cI .gcl-k3 j et stc,ses.

(.c ,f1n„_f ,tcl,l czrit^_ _allotiv_.rn._Lxcnn rtiori_Erin...,t.ii.... t€h _r_'c.r IUw.-in qtr ^^urso)ls x_]zo....

Ole ,geographical area affected by this subsection.

- _(o.)Qn,.(Tr:_'si t:,r?_u_Iy„I, ,_199aLw^h ne4er'a« tulbo .r hastier ;eci_irn sgii.etl airciralit -in_zccot.dari,

with_c.riteria contained in V: AC, 173-133-1400) for_ a geographical area defined under subsection (51 of'

thr , sec ur soo .in r resicIGnc e csz' ccsrnrri r^r r1 cst blrslrrnc nt dr tt]!rn that ;c:og <tlthi a Brea- shal. l. _nc>t

operate- any solid fuel homing device.

d? .(? i-^1 .pc:r cart gTe l3onsi131 for zt ira.. zp}^Iic ^ti^IG c^l'riT _f r.;l....l..ii..ie-v-icc- 7h.,rciy;.r7 of crtitivq.at. tl.e. tan)

an 41sod6s eclareil sht.il.withhold new solid fuel }hr the duration of the episode. A person responsible

icrl' ,it, rrt-s}ptilic.ah[ solidfuel_hurl1iri _cl€visc_fl.atrg;r_c - rfth.ad.-u _1r...... -4 -3-14)l)stfccssly€n,

f?peration at the time impaiiredair quality is declared shalt withhold new solid fuel for the duration of the

i.. so tired <r r (gu rky.. . exh ttustduct attet. threes hours hits :;lapsed

troin thc .^ c a I of tl.cccpeeod c ntp.ancd. al...gu l.tM slcs.l, l_ca3lrtitituLc pi.n .-[acic e.v.clcna c of

unlawful opetatic,n of an ap^cable solid fuel burnip device. This presumption may be refuted by

clemonstrttion Th it the srag1te_s as..p. cai s.L.t.._I?y__r:-^s.liel_ttie:l bia.ia_ ng ded is ..

#3) (5) Ecology, authoritie health dgpat'tntents. fire departments. or locaipolice forces having

cutan.liance._v-ii_l.t.rrrmn dcsicc_ urlttilinex),t,. I ulas

after three hours has ela sed from the declaration of the 3i x[e or impaired air quality.

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55
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56
Routing and Transmittal Sim

To: --

DATE: 2/22/2013

tnitias Date

^-

_

1. Jeff Hunt, OAWT - A.PU

7,13

2. Robert Kotchenruther, OEA

_

7- Z6 13

3. Alexander Fidis, ORC (a.

4. Debra Suzuki, OAWT - APU r L

5. Kate Kelly, OAWT

Approval _-- _ 1 i information

Note and Return As R e q u e s t e d

The Washington State Department of Ecology requested a "pre-submittal review" letter for the

draft. Thurston County Second 10--Year f..iinitecl Maintenance Plan in the spirit of the recent

LEAN, SIP/PIP process.

Electronic copies of all documents are available in the folder below:

G:\BalcerAl-R QUAL:.ITY1SIPTR Notices\FY 20131WA Thurston Co M110

From: Please Return To:

Jeff Hunt, AWT-107

Office of Air, Waste, and Toxies

(206) 553-0256
i