Alaska Department of

Environmental Conservation

Amendments to State Air Quality Control Plan

Volume II: Analysis of Problems, Control Action

Section III.H.1. “Interstate Transport of Lead Pollution”

Adopted

May 29, 2012

Sean Parnell

Governor 

Larry Hartig 

Commissioner
Adopted May 29, 2012

III.H-ii

This page serves as a placeholder for two-sided copying.
Adopted May 29, 2012

III.H-4

Amendments to State Air Quality Control Plan, Volume II, 

Section III.H, Subpart H.1 “Interstate Transport of Lead Pollution”

(A new section to be inserted in section III.H.)

4. PROVISIONS PROHIBITING REGIONAL TRANSPORT OF AIR POLLUTANTS

Pursuant to the requirements of the 1990 Clean Air Act (CAA) Amendments, Sections 

110(a)(2)(D)(i) (I)&(II), Alaska’s State Implementation Plan (SIP)must “contain adequate 

provision prohibiting ...any source or other type of emissions activity within the State from 

emitting any air pollutant in amounts which will—

I. contribute significantly to nonattainment in, or interfere with maintenance by, any other 

State with respect to any such national primary or secondary ambient air quality standard;

or

II. interfere with measures required to be included in the applicable implementation plan for 

any other State... to prevent significant deterioration of air quality or to protect visibility.

Alaska meets the requirements of CAA Section 110(a)(2)(D)(i)(I)&(II) as follows:

I.A. Alaska does not contribute to nonattainment in any other State with respect to the 2008 

lead primary or secondary national ambient air quality standards (NAAQS). This 

statement is based on the following information:

• At the present time (winter 2012), there are no designated lead nonattainment areas in 

Alaska or the Pacific Northwest (i.e., Washington, Oregon and Idaho). 

• Potential sources of atmospheric lead in Alaska are due primarily to the burning of 

aviation gasoline, which contains tetraethyl-lead, in piston-engine aircraft. Aviation 

gasoline is not refined or produced in Alaska. Alaska imports all of its aviation 

gasoline from one or two west coast refineries. The State of Alaska Department of 

Revenue’s Tax Division estimate for annual aviation gasoline sold in Alaska ranged 

between 16.5 million gallons in 2005 and 12.3 million gallons in 2010.1 The majority 

of Alaska’s aviation gasoline is shipped into Alaska by tanker ship from Chevron’s 

Richmond, California oil refinery through Chevron’s shipping terminal and bulk fuel 

storage facility located in Anchorage. 2

 From there, the aviation gasoline is distributed 

by truck to airports in Anchorage and Fairbanks and other interior Alaska airports 

located on the road system. 

Merrill Field airport is the largest general aviation airport in Alaska and is located 

within the Municipality of Anchorage. Merrill Field airport has the greatest potential

for public health impacts due to lead emissions from piston-engine aircraft in Alaska 

because of its close proximity to Anchorage’s population center and its heavy piston-

 1 State of Alaska, Department of Revenue, Tax Division, 2005-2009 Annual Reports. 

http://www.tax.alaska.gov/programs/sourcebook/index.aspx 2 : ADEC staff personal communication with Kirk Payne, Vice President, Delta Western, May 12th, 2010. 
Adopted May 29, 2012

III.H-5

engine aircraft traffic. Merrill Field averaged 91,063 landings and takeoffs between 

2002 and 2009.3 Average, annual aviation gasoline consumption for this same time 

period was 590,493 gallons. This results in an average, annual total lead emission rate 

of 0.7 short tons (~1,400 pounds) per year for Merrill Field. 

Ambient air quality data with regards to lead in Alaska are scarce. EPA and DEC, in 

conjunction with the Municipality of Anchorage, began monitoring for lead at the 

Merrill Field airport to determine if lead emissions from aviation gasoline used by 

piston-engine aircraft are a concern for local residents. Lead monitoring at the Merrill 

Field airport commenced on October 18, 2011. 

Source specific ambient lead monitoring related to operations at the Red Dog Mine, 

located in Noatak, has been initiated by DEC to address federal lead monitoring 

requirements. A copy of DEC’s 2012 Noatak lead monitoring plan can be found at 

DEC’s website: http://www.dec.state.ak.us/air/am/am_airmonplan.htm . 

• The Yukon Territory and the Province of British Columbia, Canada lie between 

Washington State and the border of Alaska. The southern border of Southeast Alaska is 

separated from the border of Washington State by over 500 nautical miles or 600

statute miles. The Municipality of Anchorage and Fairbanks North Star Borough have 

the highest emissions of regulated air pollutants and are located approximately 1,435 

statute miles (1,247 nautical miles) and 2,244 statute miles (1,950 nautical miles) from 

Seattle, Washington, respectively.

• In Alaska, the regional, predominant low pressure wind patterns emanate from the Gulf 

of Alaska in the west and travel inland towards the east, circulating in a 

counterclockwise direction. These predominant low pressure wind patterns would not 

generally be expected to transport lead air pollutants long distances from Alaska to 

Washington State or the Pacific Northwest. DEC concludes that Alaska does not 

contribute to nonattainment in any other State with respect to the 2008 lead primary or 

secondary NAAQS due to the distances involved, predominant weather patterns and 

scarcity of stationary lead emission sources in Alaska. 

I.B. Alaska does not interfere with maintenance by any other State with respect to the 2008

lead primary or secondary NAAQS. This statement is based on the following 

information:

• Currently (winter 2012), there are no ambient lead monitoring data available in Alaska 

to conclude whether or not Alaska interferes with maintenance of the 2008 lead 

NAAQS in any other state. 

• Alaska would not be expected to interfere with maintenance of the 2008 lead NAAQS 

in any other state because the southern border of southeast Alaska is separated from the 

border of Washington State by over 500 nautical miles or 600 statute miles. The 

 3 : ADEC staff personal communication with Darlene Sivyer, Office Manager, Merrill Field, May 11, 2010.
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III.H-6

Municipality of Anchorage and Fairbanks North Star Borough have the highest 

emissions of regulated air pollutants and are located approximately 1,435 statute miles 

(1,247 nautical miles) and 2,244 statute miles (1,950 nautical miles) from Seattle, 

Washington, respectively.

• In Alaska, the regional, predominant low pressure wind patterns emanate from the Gulf 

of Alaska in the west and travel inland towards the east, circulating in a 

counterclockwise direction. These predominant low pressure wind patterns would not 

generally be expected to transport lead air pollutants long distances from Alaska to 

points south in Washington State or the Pacific Northwest. DEC concludes that Alaska 

does not interfere with maintenance by any other State with respect to the 2008 lead 

primary or secondary NAAQS due to the distances involved, predominant weather 

patterns and scarcity of stationary lead emissions sources in Alaska. 

II.A. Alaska does not interfere with measures required to be included in the applicable 

implementation plan for any other State... to prevent significant deterioration of air 

quality. This statement is based on the following information:

• Alaska has a fully approved PSD/NSR program originally approved on February 16, 

1995 (60 FR 8943), and most recently approved on August 14, 2007 (72 FR 45378). 

Alaska adopted the 2008 lead NAAQS on February 17, 2010; this regulation became 

effective on April 1, 2010. DEC concludes that there are no stationary lead emission 

sources in Alaska that would contribute to the significant deterioration of air quality in 

another state due to the distances involved, predominant weather patterns and scarcity

of these sources in Alaska. 

II.B. Alaska does not interfere with measures required to be included in the applicable 

implementation plan for any other State... to protect visibility. This statement is based 

on the following information:

• Alaska submitted its Regional Haze SIP to EPA, in conjunction with its PM2.5 and 

Ozone Interstate Transport SIP, in a transmittal letter dated March 29, 2010 to meet the 

requirements of federal Regional Haze regulations found at 64 FR 35714 (July 1, 

1999); and to meet the requirements of EPA’s “Finding of Failure To Submit State

Implementation Plans Required by the 1999 Regional Haze Rule” as published in 74 

FR 2392 (January 15, 2009). DEC concludes that there are no new visibility protection 

obligations under CAA §110(a) (2) (D) or (J) as a result of the 2008 lead NAAQS.