J~ ~osr UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION 10 

u 1200 Sixth Avenue, Suite 900 

% = Seattle, WA 98101-3140 

~o 

'9< PROfO( `' orr-ict. orANt, wAS7T6 AND l"oxICS 

Oregon Department of Enviromnental Qtiality (DEQ) 

Air Quality Division . Attn: IZlamath Falls PM2.5 Plan 

811 SW Sixth Avenuc 

Portland,Oregon 97204-1390 

llear Klamath Falls PM2.5 Planning Tealn: 

EPA Regiotn 10 has reviewed the proposed Stale Implementa[ion Plan (SIP) for thc TClamath Falls PMzs 

nonattainmen[ area released for public colnment in August 2012, and subniits the coinments listed below. We 

would first like to cotnpliment you On your efforts working with the Klamath Falls cornmunity and local govcrnment 

to protect hmnan health and the environment. 

Resonrces and Strategy - A mmnber of the key recommendations lis[ed in the Klamath Falls Advisory Commi[tee 

report were not adopted as emissions reduction strategies or contingency measurea. A few of tttese options appetv to 

be econolnically feasible strategies and Ineastues that have been effective in areas facing sitnilar issues. 

Spccifically, i[ would be helpful to understancl why the following were not adopted as redoction sh'ategies or 

contingency measm•es: ( I) Focus enforeement of woodstove curtailment on habitual violators; (2) Ameod the 

County or[linance to mandate a minimum fine for a second burning violation; (3) Prohibit the use of all tmcertified 

wood heating atoves and inserts. Additionally, more emissions reductions inay be gaine(1 by implementing 

strategies that will incroaso colnpliance with the existing ordinancc, such as increased citations; in the past two years 

there have been 104 violations documented but only two citatioos issued. Although the current emissions reduction 

strategies have been in place since 2007, nionitoring data shows modest reductions to this point, so any additional 

measures wotdd slrongthen the areas ability to attain the standard by ,December 2014. 

Piuding ot' Insignifieance EPA is currently considering whether Ihe iZlamath Falls nonattainment area qualifies for 

a Finding of Insignificance for Motor Vehicle emissions. If EPA finds that motor vehicle emissions are a significant 

contributor m air quality problems, DEQ will need to provide a motor vehicle einissiona budget for [lte 

nonattaiomenl: area wilh the official subinission and remove the finding of insignificance from the final plan. 

13enefits of Cnrrent, New Strategies — 

• EPA's review of DEQ's lechnical information found an inconsistency in one of the calculations. Wtten 

niodified, the current strategies for the Klamath County Clean Air Ortlinance reduee PM2.5 by 9.2 ftg/m 3 

instead of by 10.9 f[g/in'. This incrcases [he l'inal 2014 design value by 2 μg/in 3 . Can you please clarify 

your calculation of the enforcement cffcctiveness on red days? 

• Our analysis of the futurc mcasure fireplace standalrl calcnlated a much smaller eniission reduction (0.2 

μg/mz) than is sta[ed in the Attainment Plan (1.2 pg/m'). This diFference would increase [he final estimated 

2014 design values by I μg/m'. Can you clarify how you arrived at 1.2 μg/m 3for the benefit of the ASTM 

fireplace standarrl in 20147 

Fireplace Measnres / Contiugency Plan - 

(1) Future measures -In the I{lamath Falls Attainmco[ Plan, credit is taken as a new strategy for 

implementxttion of the AS'1'M fireplacc slandaid of 5.1 g/kg ofPM,, S. Under section 406.100(3)(f) of the 

proposed County Ordinancc new or reurofitted fireplaces must mect fircplace ASTM standards. Under 

OAR 340-240-0630, the fireplace standard is listed as a contingency niensures that does not take effect 

untit Mareth I, 2015. If credit is to be tal:en for emissions induc[ions in the altainment demonstration as a 

new mcasm'c, then both the County Ordinance and DEQ rule neetl to be aligned to state [hat all new and 

irotrofiLLOd fireplaces will achieve the 5.1g/kg ASTM standard effective immediately. 

(2) Contingency plan — In the Rlamath Falts Attainment Plan, Phase I of the contingency plan s[ates that OAR 

340-240-0630 prohibits [he use of all fireplaces during the winter woodheating season. Thc actual text of 

a Prinfetl an Hecycletl Paper 
OAR 340-240-0630, however, does not correspond to the state nent in lhe plan bu[ inatead only prohibits 

einissions exceeding the ASTM standard on Fireplaces installed after March I, 2015. Klaniath Falls 

Ordinance 406.500(2) prohibits the use of non-certified fireplacea during Ihe heating season as a 

contingeney measure. If the intent of the contingency measure is [o prohibit the use of Pireplacea not 

meeting tlie ASTM standarcl in the winter months, we recommencl OAR 340-240-630 be redrafted to be 

consistent with Klainath Falls proposed ordinance 406.500(2) which prohibits the use of fireplaces not 

meeting [he ASTM standarcl between November I and February 28 each winter ttcating season. IP this is 

not the intent of the contingency measure then lhe plan statement rel'eeenced above must be corrected. 

Rtde Language 

• Divisions 225-0090 and 240-0550 - While it is acceptable to allow ofPscts from permanent woodstove 

einission recluctions and it is acceptable to revise lhe provisions for deinonstrating that the wooclstove 

offsels provide for a net air quality benefit, Ihe proposed language goes too far in that it does not ensure th2t 

lhe emissions Gom the new or modified major source wouldn't cause a new violation in [he nonattainment 

area. Rather than a cotnplete exeinp[ion fi -oin the requirement for a net air quality beneri[ in paragraph 225- 

0090 (2)(a)(E), [he rule must include a new provision in paragraph (E) similar to the safcguards in the 

provision for small scale local energy projeets. 

• Division 240 - OAR 340-240-0570 states tha[ all of the contingency provisions "apply to the Klainath Falls 

NonattainmenC Area for PM2.5 shoulcl the area not achieve attainment by the applicable Clean Air Act 

deadline." The phrasing "applicable Clean Air Act deadline" is not defined in the regulations nor does it 

contain a cita[ion [o the couurolling autbority es[ablishing the attainment date. We suggest revising to: 

"...should (lie area not achieve attainment by the applicable attainment date oPDeceinber 14, 2014.", or 

"should the area not acfhieve attainment by the applicable attainment date established pursuant to 42 U.S.C. 

7502(a)(2)." 

• Division 262 —If you retain [he 20°l0 opacity standard it cannot be eonsidered a contingeney measure as it is 

already iniplemented in Klamath Cotm[y ordinance 406.150. However, we are supportive of a general 20% 

opacity standard or O% (no visible emissions) standard cluring burn bans. 

Appendices - It is very difficult to identify and navigate the contents or the multiple appendix files. Please include 

a lable of contents for the appendices in the attainment plan. It may also improve navigability by reducing the total 

iiuntber of I'iles. 

Thank you for the opportunity ancl please take tliem into consideration for the Klamath Falls PM2.5 Attainment 

Rulemaldng. If you have any questions, please feel free to contact Justin A. Spenillo via phone or einail 

(206.553.6125, Sl2enillo.ju.stin(0epai2v). 

Regarcls, 

~ 

Debra Suzuki, Manager U 

Sta[e and Tribal Air Program Unit 

~ Pdntetl on Necyclstl Paper