ONlS "TREY" GLENN, Ill 

DIRECTOR " ADEM " 

Alabama Department of Environmental Mana@menti 

adem.alabama.gov 2.s 

1400 Col~seum Blvd 361 10 2059 * Post Office Box 301 463 

Montgomery, Alabama 36130-1463 "--p 

(334) 271-7700 '""'ad' 25 p ?: - 

FAX (334) 271-7950 30 

September 23, 2009 

CERTIFIED MAIL NO: 91 7108 2133 3935 2910 2519 

RETlJRN RECEIPT REQUESTED 

Mr. A. Stanley Meiburg 

Regional Administrator, 

Atlanta Federal Center 

61 Forsyth Street, S.W. 

This letter is to certify that Alabama's existing State Implementation Plan (SIP) meets 

all Section 1 10 (a)(2) provisions of the Clean Air Act (CAA) that address the 

requirements for the 2006 particulate matter NAAQS. This infrastructure SIP 

underwent public notice from August 2 to September 18, 2009. The attached table 

specifies how Alabama's SIP addresses these elements. 

Also included is a letter to EPA from Alabama Department of Environmental 

Management certifying that the State Implementation Plan fulfills the 1 lO(a)(2)(G) 

CAA requirements for emergency episode planning for fine particles (PM2.5). 

If you need additional information concerning this submittal, please call Chris Howard 

of my staff at (334) 271-7878. 

Sincerely, 

Ronald W. Gore, Chief 

Air Division 

2 Enclosures 

Birmingham Branch Decatur Branch 

11 0Vulian Road 2715 Sandl~n Road, 8 W 

B~rm~ngham, AL 35209-4702 Decatur, AL 35603-1 333 

(205) 942-61 68 (256) 351-1713 

(205) 941 -1 603 (Fax) (256) 34n-9359 (Fax) 

BOB RILEY 

GOVERNOR 

Mobile Branch 

2204 Per~meter Road 

Mobtle,AL 36615-1 131 

(251) 450-3400 

(25 1) 479-2593 (Fax) 

Mobile -Coastal 

4171 Commanders Drwe 

Mobile, AL 3661 5-142 1 

(251) 432-6533 

(251) 432-6598 (Fax) 

Akba~ Department d Envlmnmd M#~lgmont 

BOB RILEY 

GOVERNOR 

Idomak-.gw 

1400 Cdiseum Slvd. 361 10-N59 * Post Ofhce Box 301 963 

Montgomery, Abbarna 361 30-1463 

(334) 271-7700 

FAX (334) 271 -7%O 

September 18,2008 

Mr. James I. Palmer, Jr. 

Regional Administrator, EPA Region 4 

Atlanta Federal Center 

61 Forsyth Street, S.W. 

Atlanta, Gwrgia 30303-8960 

Dear Mr. Palmer: 

This letter certifies that the existing Alabama Department of Environmental Management 

(ADEM) State Implementation Plan (SIP) fblfills the 110(a)(2)(G) Clean Air Act (CAA) requirements for 

emergency episode planning for fine particles (PM2 s). The purpose of this letter is to provide verification 

that ADEM has the authority to administer emergency episode plans, and to provide information showing 

that Alabama would qualify as a Class 111 Priority Area under EPA's proposed classification scheme. This 

classification would exempt Alabama from the necessity of adopting an Emergency Episode Plan for 

PM2 5. 

Pursuant to Ah Code $22-28-1 1 and $22-28-14 (2006 Rplc. Vol,), ADEM is authorized to 

implement emergency air pollution episode measures. 

The requirement for a state to submit an emergency episode plan is based on a priority region 

classification. For PM2,J, the classification scheme that EPA is planning to propose would require states 

with any 24-hour PM2,5 concentration above 140.5 pglm3 (using the most recent three years of data) to 

develop an emergency episode plan. States that do not meet this threshold would be classified as Priority 

I11 and would not be required to develop an emergency episode plan for PM2 5. Based on these criteria, 

Alabama would be classified as a Class 111 Priority Area and therefore should not be required to adopt an 

Emergency Episode Plan for PM2.5 because no concentrations above the 140.5 pgIm3 threshold have been 

measured. 

If you have any questions, please call Ron Gore, Chief of the Air Division, at 334-271-7868. 

Sincerely, 

#j'& M. 

Onis "Tre Glenn, 111 

Director 

Blrmlngham Branch kcatur Branch 

I 10 Vulcdn Road 2715 SandltnRoad 5 W. 

Birm~ngham. Al 352094702 Decatur. AL 35603-1 333 

1205) '34261 68 (256) 353-1713 

(2051 94 I- 1603 (Faxi (256) 340-9359 Fax) 

Wle BTanch MobMe - Codrtd 

22M Per~merer Rcdd 4171 Commanders Urwe 

Mctnle, AL 3t6lS-ll3l Mobile, AL 36615-1421 

(25 1) 450-3403 1251) 4326533 

1251) 479-2593 (Fax) (251 14326598 Fax) 

ATTACHMENT - SIP SUBMllTAL COMPLETENESS CRITERIA CHECKLIST 

bject: Confirmation of 1 lO(a)(2)(A)-(M) PM NAAQS Requirements in the Current Alabama SIP 

1 dO(a)(2)(A)-(M) Requirements Checklist - Alabama 

mary of element 

de enforceable emission limitations and other 

ol measures, means. or techniques (including 

omic incentives such as fees, marketable 

its, and auctions of emissions rights), as well 

hedules and timetables for compliance as may 

ecessary or appropriate to meet the applicable 

rements of this Act. 

de for establishment and operation of 

opriate devices, methods, systems, and 

edures necessary to- 

4 monitor, compile, and analyze data on ambient air quality, and 

ii) upon request, make such data available 

to the Administrator; 

de a program to provide for the enforcement of 

measures described in subparagraph (A) and 

ation of the modification and construction of 

tationary source within the areas covered by 

lan as necessary to assure that national 

ent air quality standards are achieved, 

ding a permit program as required in parts C 

D; 

How Addressed in Submittal 

These requirements are met through ADEM Admin. Code rs. 335-3-1- 

.03 "Ambient Air Quality Standards", 335-3-1-.05 "Sampling and Testing 

Methods", 335-3-1-.06 "Compliance Schedule", and 335-3-14-.03(1)(g) 

"Standards for Granting Permits". Further, the following rules regulate 

stack height: 335-3-14-.03(2)(d) & (e), 335-3-15-.02(9)(d) & (e), 335-3- 

16-.02(1 O)(d) & (e). 

These requirements are met through ADEM Admin. Code rs. 335-3-1- 

.04 "Monitoring, Records, and Reporting" and 335-3-1-.05 "Sampling 

and Testing Methods". Further, our 2008 network plan was conditionally 

approved by EPA on October 27,2008, and ADEM responded on 

December 22, 2008. 

ADEM commits to ensuring that PSD and Nonattainment NSR permits 

issued to major sources in Alabama will be consistent with Alabama's 

approved SIP regarding such permits. According to EPA's 

"Implementation of the New Source Review (NSR) Program for PM2.5" 

published May 16, 2008, states with EPA approved PSD programs 

should continue to use the existing interim approach of relying on PMlO 

as a surrogate for PM2.5 until their revised SIPS are adopted. In 

nonattainment areas of the state, the 'transitional' NSR provisions 

(contained in Appendix S of 40 CFR 51) are to be applied until a revised 

SIP is adopted. ADEM is able to regulate sources of PMlO through 

ADEM Admin. Code rs. 335-3-14-.04 "Prevention of Significant 

Deterioration in Permitting" and 335-3-14-.05 "Air Permits Authorizing 

Construction in or Near Nonattainment Areas". 

Page 1 
Section IlO(a) element 1 Summary of element 

(i) prohibiting, consistent with the provisions of 

this title, 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 

(11) interfere with measures required to be 

included in the applicable implementation plan for any other Sfate under part C to prevent significant 

deterioration of air quality or to protect visibility, 

How Addressed in Submittal 

$1 Wa)(2)(D) 

(ii) insuring compliance with the applicable 

requirements of sections 126 and 115 (relating to 

contain adequate provisionsI interstate and international pollution abatement); 

[ provide 

(I) necessary assurances that the state (or, except 

where the Administrator deems inappropriate, the 

general purpose local government or governments, 

or a regional agency designated by the state or 

general purpose local governmenfs for such 

purpose) will have adequate personnel, funding, 

and authority under state (and, as appropriate, 

local) law to carry out such implementation plan 

(and is not prohibited by any provision of federal or 

state law from carrying out such implementation 

plan or portion thereof); 

The first and second elements are met throug

Interstate Rule (CAIR), which was approved b

(72 FR 55659). The fourth element is met thr

Haze lmplementation Plan, which was submit

As stated previously, concerning the third elem

ensuring that PSD and Nonattainment NSR p

sources in Alabama will be consistent with Alaregarding such permits. According to EPA's "

Source Review (NSR) Program for PM2.5" pu

states with EPA approved PSD programs sho

existing interim approach of relying on PMIO a

until their revised SIPS are adopted. In nonatt

the 'transitional' NSR provisions (contained in 

are to be applied until a revised SIP is adopte

regulate sources of PMlO through ADEM Adm

"Prevention of Significant Deterioration in Per"Air Permits Authorizing Construction in or Ne

Legal authority is derived from Ala. Code §22

which authorizes the Department to adopt em

through regulation that are necessary to preve

pollution. The funding requirements are met t

through the Title V fee process (ADEM Admin

Page 2 
that, where the state has 

d on a local or regional government, agency, or 

rumentality for the implementation of any plan 

vision, the state has responsibility for ensuring 

quate implementation of such plan provision; 

uire, as may be prescribed by the 

mmary of element 

equirements that the state comply with the 

uirements respecting state boards under section 

 and 

ministratorHow Addressed in Submittal 

 the installation, maintenance, and replacement 

quipment, and the implementation of other 

essary steps by owners or operators of 

onary sources to monitor emissions from such 

rces, 

1) periodic reports on the nature and amounts of 

ssions and emissions-related data from such 

rces, and 

Ala.Codes22-22A-6(j) which ensures 

128 of the CAA 

Requirements dictating the roles of local or regional governments (local 

programs) are derived from Ala. Code §22-28-23 (2006 Rplc. Vol.), 

which do not allow the local programs to be less strict than the Alabama 

SIPIregulations and allows for oversight from the Alabama Environmental Management Commission 

These requirements are met through ADEM Admin. Code chap. 335-3- 

12 "Continuous Monitoring Requirements for Existing Sources". 

correlation of such reports by the state agency / 

 any emission limitations or standards I 

blished pursuant to this Act, which reports shall 1 

vailable at reasonable times for public I 

Page 3 

ection; 1 

vide for authority comparable to that in section 

and adequate contingency plans to implement 

h authority; 

This requirement is met through ADEM Admin. Code chap. 335-3-2, "Air 

Pollution Emergency" for PM10. In a September 18, 2008, letter to 

EPA, ADEM certified that this requirement is met for PM 2.5. 
Section 110(a) element 

(Section 127 public 

notification) 

Summary of element How Addressed in Submittal 

provide for revision of such plan- 

(I) from time to time as may be necessary to 

take account of revisions of such national primary 

or secondary ambient air quality standard or the 

availability of improved or more expeditious 

methods of attaining such standard, and (iio except as provided in paragraph (3)(C), 

whenever the Administrator finds on the basis of 

information available to the Administrator that the 

plan is substantially inadequate to attain the 

national ambient air quality standard which it 

implements, or to otherwise comply with any 

additional requirements established under this 

Act: 

in the case of a plan or plan revision for an area 

designated as a nonattainment area, meet the 

applicable requirements of part D (relating to 

nonattainment areas); meet the applicable requirements of section 121 

(relating to consultation), . . . 

meet the applicable requirements of section 7427 of 

this title, 

Page 4 

These requirements are met through ADEM Ad

.03(l)(b) and 335-3-1-.03 "Ambient Air Quality 

ADEM submitted an attainment plan for the Bir

nonattainment area on May 13, 2009. Further, 

working with Chattanooga, TN and Georgia to 

attainment plan for Jackson County, AL. In reg

Alabama has an approved conformity SIP This requirement is met through provisions in s

plans, such as the Regional Haze Implementat

for continued consultation with government offi

also met through the interagency consultation p

Alabama's approved Conformity SIP and 40 CF

This requirement is met through ADEM Admin. 

Poilution Emergency", 335-3-14-.01(7) "Public 

14-.05(13) "Public Participation". Further, ADE

notice mechanisms in place to notify the public 

forecasting. These mechanisms include issuinforecasts for both Ozone and PM2.5. Ozone fo

three areas of the state: Birmingham (Jefferson 

Huntsville (Madison and Morgan Counties) and 

Baldwin Counties). In addition, PM2.5 forecast

areas: Huntsville and Phenix City/Columbus, G

Air Quality forecasts are designed to help areas 
mmary of element 

t the applicable requirements of . . . part C 

ating to prevention of significant deterioration of 

uality and visibility protection); 

vide for: 

 the performance of such air quality modeling as 

Administrator may prescribe for the purpose of 

dicting the effect on ambient air quality of any 

ssions of any air pollutant for which the 

ministrator has established a national ambient air 

ity standard, and 

0 the submission, upon request, of data related 

uch air quality modeling to the Administrator; 

uire the owner or operator of each major 

ionary source to pay to the permitting authority, 

a condition of any permit required under this Act, 

e sufficient to cover- 

the reasonable costs of reviewing and acting 

n any application for such a permit, and 

i) if the owner or operator receives a permit for 

 source, the reasonable costs of im~lementina 

enforcjnGhe - terms and cond~tions ifany su& 

How Addressed in Submittal 

compliance with the National ~mbient Air Quality Standards (NAAQS) 

and to also allow citizens to make informed decisions about their daily 

outdoor activities. The forecasts are provided to the public in several 

ways. First, the forecast is posted to the EPA Airnow website, and 

through Enviroflash individuals can sign up to receive customized 

forecasts through email. Additionally, the forecast is posted on ADEM's 

website for the public to view. When air quality is expected to be poor, 

an Air Quality Alert is issued for a city and the local National Weather 

Service office is alerted and the forecast is posted on their website. 

Additionally, for some cities like Birmingham, the county planning 

organizations are alerted and the forecast is distributed to the media, 

and other interested groups. 

This requirement is met through ADEM Admin. Code chap. 335-3-14 "Air 

Permits" and through the Alabama Regional Haze Implementation Plan, 

which was submitted July 15, 2008. This requirement is met through ADEM Admin. Code rs. 335-3-1-.04 

"Monitoring, Records, and Reporting" and 335-3-14-.04 "Prevention of Significant Deterioration Permitting", specifically paragraph (1 1) "Air 

Quality Models". 

This requirement is met through ADEM Admin. Code chap. 335-1-7 "Air 

Division Operating Permit Fees", which are State regulations not 

approved in the Federal SIP. 

Page 5 
Section 110(a) element Summary of element 

permit (not including any court costs or other costs 

associated with any enforcement action), until such fee requirement is superseded with respect to such 

sources by the Administrator's approval of a fee 

program under title V; 

provide for consultation and participation by local 

political subdivisions affected by the plan. 

Part C Permit program: 

$1 10(a)(2) (J) meet the applicable requirements of 

. . . part C (relating to prevention of significant 

deterioration of air quality and visibility protection); 

51 10(a)(2)(C) . . . regulation of the modification and 

construction of any stationary source within the 

areas covered by the plan as necessary to assure 

that national ambient air quality standards are 

achieved, including a permit program as required in 

parts C and D; 

40 CFR 51.166: Amend PSD regulations as 

required by the November 29, 2005 final rule (70 FR 

71612 at 71699-71700). See also 70 FR 71671- 

71 684. 

How Addressed in Submittal 

This requirement is met through ADEM Admin. "Transportation Conformity". This requirement 

interagency consultation process as directed by 

Conformity SIP and 40 CFR 93.112. 

Page 6