UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 10

1200 Sixth Avenue, Suite 900

Seattle, WA 98101-3140

OFFICE OF

AIR, WASTE AND TOXICS

OCT 0 3 2014

Stu Clark

Air Quality Program Manager

Washington State Department of Ecology

P.O. Box 47600

Olympia, WA 98504-7600

Re: Completeness Determination for the Multi-pollutant Infrastructure SIP Submission

Dear Mr. Clark:

This letter is in response to your September 22, 2014 submission related to Clean Air Act (CAA)

sections 1 l0(a)(1) and (2), "Infrastructure SIP Revision for the 2010 Nitrogen Dioxide, 2008

Ozone, and 1997, 2006, and 2012 Fine Particulate Matter National Ambient Air Quality

Standards." This submission is intended to demonstrate that the State of Washington has the

necessary infrastructure to implement the air quality management requirements set forth in

sections 110(a)(1) and (2) of the CAA with respect to these air quality standards.

Specifically, Washington's submission addresses the following CAA section 110(a)(2)

infrastructure elements: (A), (B), (C) - except for those elements covered by the Prevention of

Significant Deterioration (PSD) Federal Implementation Plan (FIP), (D)(i)(II) - except for those

elements covered by the PSD and regional haze FIPs, (D)(ii) - except for those elements covered

by the PSD FIP, (E), (F), (G), (H), (J) - except for those elements covered by the PSD FIP, (K),

(L), and (M). The Environmental Protection Agency (EPA) notes that the Washington

Department of Ecology (Ecology) intends to address the CAA section 110(a)(2)(D)(i)(I)

interstate transport provisions in a separate submittal.

The EPA has determined that the submission is complete for the specific elements described

above for the air quality standards addressed. The EPA also notes that on January 27, 2014,

Ecology submitted significant updates to Chapter 173-400 Washington Administrative Code

(WAC), including provisions covering Ecology's PSD program. The EPA has already acted

upon parts of the January 27, 2014 submittal, but we have not yet completed our review of

Ecology's PSD program. The EPA also notes that the January 27, 2014 submission only covers

PSD requirements for sources under Ecology's jurisdiction. So even after a final determination

is made by the EPA regarding the January 27, 2014 submission, Ecology's PSD submission

would not be considered complete for the PSD infrastructure requirements because it does not

cover all facilities in Washington, such as those under the jurisdiction of the Energy Facilities

Site Evaluation Council.

As discussed in previous infrastructure actions for both ozone and lead (77 FR 30902, May 24,

2012 and 79 FR 42683, July 23, 2014), the EPA anticipates that there would be no adverse

*Printed on Recycled Paper
consequences to Washington or to sources in the state resulting from relying on the existing PSD

and regional haze FIPs to satisfy infrastructure requirements. The EPA anticipates no additional

FIP responsibilities for PSD and regional haze as a result of the determination that the September

22, 2014 infrastructure submission is not complete for those elements. We note that we are

working with Ecology on a separate submission addressing the remaining CAA section

110(a)(2)(D)(i)(I) interstate transport requirements.

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

contact Debra Suzuki, Air Planning Unit Manager, at (206) 553-0985 or Jeff Hunt, staff lead, at

206-553-0256.

Sincerely,

4 Kate Kelly, Director

Office of Air, Waste, and Toxics