# STATE OF COLORI\DO
John W. Hbkenlooper, Governor Christopher E. Urbina, MD, MPH

Executive Director and Chief Medical Officer Dedicated :o protecting and improving the health and environment of the people ofColorado 4300 Cherry Creek Dr. S. Laboratory Services Division Denver, Colorado 80246-1530 E100 Lowry Blvd. Phone (303) 692-2000 Denver, Colorado 80230·6928 Located in Glendale, Colorado (303) 692-3090 http://www.cdphe.state.co.us 

### July 26, 2012 Carl Daly, AirProgram Director U.S. Environmental Protection Agency Region 8, Mail Code 8P-AR 1595 Wynkoop St. Denver, Colorado 80202-1129
DearMr. Daly: Colorado Department 

### ofPublicHealth andEnvironment



### I am submittingthis letter and attachment in response to the U
.S. Environmental Protection Agency's request to certify that Colorado meets the requirements ofSection 110(a)(1) and (2) ofthe Clean AirAct for the 2008 Lead National Ambient Air Quality Standards. Colorado has a well developed regulatory program that meets the "infrastructure" elements for State Implementation Plans (SIPs) as outlined in CAA Section llO(a)(l) and (2) for all NAAQS. The attached document, which has beenthrough a 30-day public commentperiod, outlines the Colorado provisions, programs and efforts to meetthe requirements ofSection llO(a) (1) and (2) ofthe Clean Air Act. The document is not intended to modify or amend any portion orprovision ofColorado's SIP. Sincerely,

Dr. Christopher E
. Urbina Execu tive Director and ChiefMedical Officer

cc: Scott Jackson, Acting Unit Chief, Air Quality Planning and Management Unit, EPA Region 8 

# V Kathy Ayala, Air Quality Planning and Management Unit, EPA Region 8 William Allison, Director, Air Pollution Control Division, CDPHE Michael Silverstein, Administrator and Technical Secretary, Air 

### Quality Control Commission Attachment

### State ofColorado Provisions to Meet the Requirements of Section llO(a) (1) and (2) of th e Clean Air

### Act
Section 110 (a)(l) State Implementation Plan for National AmbientAir Quality Standards Colorado has established the following StateImplementation Plan local elements to address criteriapollutants 

### in areas thathave violated the National Am bient

### Air Quality Standards (NAAQS)

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**~:~{;1;.~~:l.11~$:~"'.-::~.·!** 1-HourOzone Denver Attainment since 2001 1997 8-HourOzone
. NorthernFrontRange Ozone Nonattainment

**effe~tive** November 20,2007. Ozone Area ActionPlan SIP revision submitted to EPA June 18, 2009. Approved by EPA, August 5, 2011 (76FR47443) Ni trogen Oxide Denver Attainment since 1984 Lead Denver Attainment since 1984 Carbon Monoxide Colorado Springs Attainment since 1999 Carbon Monoxide Denver Attamment since 2002 Carbon Monoxide Fort Collins Attainment since 2003 Carbon Monoxide Greeley Attainment since 1999 Carbon Monoxide Longmont Attainment since 1999 PM IO Aspen Attainment since 2003 PMlO Canon City Attabunent since 2001 PMlO Denver Attainment since 2002 PMlO Lamar Attainment since2005 PMlO Pagosa Springs Attainme nt since2001 PMlO Steamboat Springs Attainment since2004 PMlO Telluride Attainment since 2001 

### Section 110 (a)(2)( A)

- Emission Limits and Other Control Measures Enforceable emission limits and contr ol measures are de tailed 

### in the var ious Air Quality Contr ol Commissionregulations for all sources ofcriteria pollutants, regulated New Source Review pollutants, as well as hazardous airpollu tants, CFCs, smoke and odors. A summary ofthe regulations is found belowunder section 110 (a)(2)(C). The enforceable emission limits also apply to periods of startup, shutdown andmalfunction. The Colorado Comm onProvisions Regulat ion, Sections II. E
. and II. 

### J. contain emission con trol prov isions specific to startup, shutdown and malfunction events that are 

### in Colorado' s SIP, which was approved by EPA on August 

### 7, 2008 

### (73 F R 4587 9). 

### Section 110 (a)(2)(B) - Ambient Air 

### Quality Monitoring and Data System The provisions for episode monitoring, data compilation and reporting, public availability of information, an d annual network reviews are f ound 

### in the federally-approved statewide monitoring SIP 

### (58 FR 49435).

- 1 - Colorado 110 SIP Elements

- 2008 Lead NAAQS July 26 , 2012As part of the Monitoring SIP, Colorado submits a Colorado Annual Monitoring Network Plan each year for E PA approval. The plan details monitoring locations for all criteria pollutants, including the EPA's lead monitoring requirements under the the 2008 l ead NAAQS, and lists the quality assurance accuracy audits and precision check methods performed for each monitor. The Colorado Air Pollution Contro l Division (Division) periodically submits a Quality Management Plan and a Quality Assurance Project Plan to EPA Region VIII . These plans cover procedures to monitor, analyze data and report data to an EPA central database. The State of Colorado has an approved monitoring SIP, a plan and authority for monitoring, and the ability to properly handle all related data. Section 110 (a)(2)( C)
- Program for Enforcement of Control Measures Colorado has an approved SIP regulating the construction and modification of stationary sources as necessary to assure that the NAAQS are achieved (Colorado Air Quality Control Commission Regulation 3), including a New Source Review (NSR) permitting program as required in Title I, Parts C and D of the federal Clean Air Act. Colorado has an approved SIP which provides for the enforcement of the control measures required by Clean Air Act Section 110 (a)(2)(C). Many of the Colorado Air Quality Control Commission regulations address, in some manner, the programs for enforcement of control measures. Some of these r egulations and other relevant Colorado-specific programs that are in the SIP are described below: • Regulation 1, Particulates, Smokes , Carbon Monoxide, and Sulfur Dioxides -- Regulation 1 sets forth emissions limitations, equipment requirements, and work practices (abatement and control measures) intended to control the emissions of particulates, smoke and sulfur oxides from new and existing stationary sources. Control measures specified in this regulation are designed to limit emissions into the atmosphere and thereby rninirnize the ambient concentrations of particulates and sulfur dioxides. • Regulation 3, Stationary Source Permitting and Air Pollution Emission Notice Requirements

-- Regulation 3 provides for a procedural permitting program and requires air pollution sources to file Air Pollutant E missions Notices (APENs). The regulation also requires that new or modified sources of air pollution, with certain exemptions, obtain preconstruction permits, and to meet the federal re quirements of Prevention of Significant Deterioration (PSD) and Non-attainment New Source Review (NNSR. Colorado's NSR program applies to all regulated NSR pollutants, including GHGs. Regulation 3 has been revised to incorporate PM2.5 emissions. On May 16, 2008, October 20, 2010, April6, 2011 and May 18, 2011, EPA promulgated a series of rules regarding the regulation ofPM2.5 under the NSR permitting program. On November 15,2007, Colorado's Air Quality Control Commission adopted rule revisions that incorporated PM2.5 into the APEN and minor source permitting programs. EPA promulgated its fmal PM2.5 NSR Implementation Rules in 2010, which specifies how PM2.5 emissions are treated for PSD and major source NSR sources. On October 20,2011, Colorado's Air Quality Control Commission adopted rule revisions requiring major sources in the state to be subject to PSD and - 2 - Colorado 1 10 SIP El ements - 2008 L e ad N AAQS July 26 , 2012NSRpermitting thresholds for PM2.5 atthe samelevel as PM1 0. TP.e 2007 revision was submitted to the EPAin2008. The 2011 revision is currently under Colorado legislative review. Upon completion ofthatprocess, the revision will be submittedto EPA. Colorado's minor source and PSD permittingprograms applyto sources that emit GHGin accordance withEPA's Tailoring Rule. The Colorado Air Quality Control Commission on October 21, 2010, adopted revisions throughout Regulation Number 3 to address GHG regulation in Colorado. These revisions were made to incorporate EPA's GHG Tailoring
. Rule into Colorado's Title V and PSD Permitting Programs, andto extend synthetic minor permitting to Colorado's stationary sources seeking federally enforceable limits to avoid major source ormajor stationary source applicability thresholds specific to GHG. On October 20, 2011, Colorado's 

### Air Quality Control Commission adopted rule revisions that incorporated EPA's Biogenic C02Deferral into Regulation 3. The 2010 revision was submitted to EPA in 2011. The 2011 revision is currentlyunder Colorado legislative review. Upon completion ofthat process, the revision will be submitted to EPA
. Regulation 3 also was revised in 2008 to address ozone formation inthe Denver Metro Area/North Front Range Ozone nonattainment area. Specifically, the Commission adopted revisions to remove and/or revise several categorical APEN reporting and/or permitting exemptions in order to improvethe Division's emissions inventory and for the sake ofequity
. Therevisions arepart ofthe federally-enforceable SIP and help Colorado make progress toward eventual compliance withthe 2008 ozoneNAAQS set at 0.075 ppm.**~** Regulation 4, Woodburning Controls-- Regulation 4 requires that new woodstove and fireplace inserts meet the federal certificationrequirements in specified areas ofColorado.**~** Regulation 7, Control ofOzone via Ozone Precursors andNitrogen Oxides

-- Regulation 7 controls the emissions ofvolatile organic compounds, primarily inthe Denver-metro area 

### It sets standards and mandates controls for specific types ofvolatile organic compound sources. 

### In 2008, Regulation 7 wasrevised to increase control requirements for oil and gas condensate tanks, glycol dehydrators and reciprocating internal combustion engines. These revisions were submitted to EPAin 2009 as part ofthe state's Ozone State Implementation Plan. EPA approvedthe associated Ozone attainment demonstration.**~** Regulation 11, Motor Vehicle Inspection-- Regulation 11 requires automobile emission inspection and maintenance programs to be implemented in specified areas ofthe state for gasoline powered on-road vehi.cles. These programs apply to businesses, industry, and the general public. 

### Inaddition, the State's Automobile Inspection andReadjustment (AIR) program'spurpose is to reduce motor vehicle related pollution through the inspection and emissions related repair ofautomobiles. The program, as defmed inRegulation 11 , works in specific areas ofthe State ofColorado and requires motor vehicles tomeetemission standards through periodic inspection and, as necessary, repair.**~** Regulation 16, Street Sanding and Sweeping

-- Regulation 16 sets specification standards for street sanding material and street sweepingpractices 

### inthe Automobile Inspection and Readjustment program area and Denver

-metro particulate attainment/maintenance area. - 3

- Colorado 1 10 SI P Elem ents
- 2008 Lead N AAQ S J ul y 26 , 201 2**~** Common Provisions Regulation

-- The Division may require owners and operators of stationary air pollution sources to install, maintain, and use instrumentation to monitor and record emission data as a basis for periodic reports to the Division under the provisions of the Colorado Air Quality Control Commission Common Provisions regulation. Also, the Common Provisions Regulation contains emission control provisions specific to startup, shutdown and malfunction events that are in Colorado's SIP, which was approved by EPA on August 7, 2008 (73 FR 45879). Section 110 (a)(2)(D)(i) - Interstate Transport For interstate transport, the SIP needs to contain four provisions to ensure that Colorado emissions and pollutants do not: · • significantly contribute to nonattainment in another State (Prong 1 ); • interfere with maintenance of the NAAQS by another State (Prong 2); • interfere with another State's measures to prevent significant deterioration of air quality (Prong 3); and • interfere with another State's measures to protect visibility (Prong 4). Colorado has addressed federal interstate transport requirements for the 1997 ozone and PM2 . 5 NAAQS with an interstate transport SIP revi s ion submitted to EPA March 31, 2010. EPA has since approved all four prongs of Interstate Transport for both the 1997 Ozone and PM2.5 standards. With regards to the 2006 PM2 .5 standard, the Colorado Air Quality Control Commission approved an Interstate Transport SIP in December 2011, which was submitted to EPA May 11. With regards to lead, Colorado has assessed whether or not any lead sources are within 2 miles of the state border or emit more than 0.5 tons per year oflead. No sources meet these criteria in Colorado, the demonstration of which should satisfy prongs 1 and 2 of futerstate Transport for lead, according to the fmal guidance on lead infrastructure SIPs released by E PA on October 14 , 20 11. An appendix showing Colorado's lead inventory is attached. Prong 3 of Interstate Transport deals with prevention of significant deterioration. As explained under section 110 (a)(2)(C), Colorado has revised its SIP through revisions to Regulation No.3 in 2007, 2010 and 2011 to have a PSD program that meets all federal requirements and that applies to all regulated NSR pollutants. ·

Thus, the implementation of Colorado's PSD and NNSR permitting programs prevent significant deterioration in neighboring states and thereby satisfy the PSD portion of 110(a)(2)(D)(i)(II) of the CAA. Colorado's PSD and NNSR permitting programs require that demonstrations be made for all areas that are potentially impacted by emissions from a proposed major source or modification. A PSD permit may not be issued unless the new or modified source demonstrates that emissions from the construction or operation of the facility will not cause or contribute to air pollution in any area that exceeds any NAAQS. - 4 - Colorado 110 SIP Elements - 2008 Lead. NAAQS July 26 , 2012A NNSRpermit may not be issued unless the source shows it has obtained sufficient emissions reductions to offset increases inemissions ofthe pollutants for which an area is innonattainment, consistent withreasonable further progress toward attainment. Prong 4 ofInterstate Transport relates to visibility. EPA gave preliminary approval to Colorado's Regional Haze SIP onMarch 8, 2012, and published its notice ofproposed approval onMarch 26, 2012 (77

### FR 18052). Colorado relies onits Regional Haze SIP to demonstrate thatthe state does not interfere with visibility in any other state. 

### Section 110 (a)(2)(D)(ii)- Interstate and International Transport The EPA guidance from October 14,2011,indicates that states have no obligation atthis time under Sections 115, 126 (b) and 126(c) ofthe CAAregarding interstate or international transport because there ate no petitions orpending actions before EPA underthese sections. Furthermore, the control measures inthe SIP protect not only Colorado from NAAQS violations, but neighboring states and countries as well. However, the guidance indicates an obligation under Section 126(a) that directs each SIP to include provisions requiring new ormodified sources to notify neighboring states ofpotential impacts from the sources. Colorado's approved NSRprogram has a regulatory provision inplace that requires notification ofneighboring states ofpotential impacts from sources, specifically, RegulationNo. 3, PartD, Section IV, provides for notice to any ·state, tribal governing body, federal land manager or local agency that may be affected by emissions from a major source or major modification subjectto the PSD program. 

### Clean AirAct Section 110 (a)(2)(E)- Adequate Resources, State Boards, and Authority Personnel, Funding, and Authority There are no state orfederal provisions prohibiting the implementation ofanyprovision ofthe Colorado SIP. In general, Colorado provides. the necessary assurances that funding, personnel, and

. au thority exist and that the State ofColorado has responsibility for implementing local provisions. The 

### Air Quality Control Commission adopted all ofthe regulatory provisions inthe SIP pursuant to authority delegated to it by statute. The Commission's general authorityto adopt therules and regulations necessaryto implementthe SIP is set outinthe Colorado 

### AirPollution Prevention and Control Act Section 25-7-105 ofthe Colorado Revised Statutes (C.R.S.). The general authority for the Division to administer and enforcetheprogram is set out at 25-7-111, C.R.S. Additional authority to regulate 

### air pollution and implement provisions inthe SIP is set outelsewhere inthe Colorado 

### AirPollution Prevention and Control Act, Article 7 ofTitle 25. In addition, the Commission and the Divisionhave the authority delegated to themin Sections 42-4-301 through 42-4-316,
.C.R.S. {concerning motorvehicle emissions) and 42-4-414, C.R.S. (concerning emissions from diesel-powered vehicles). The 

### Air Quality Control Commission's authority includes the authority to regulate particulate emissions, regardless ofsize (Section 25-7-109 (2)(b), C.R.S.).

- 5

- Colorado 1 10 SIP Element s - 2008 Lead N AAQ S J uly 2 6, 20 1 2The Division has staff and an annual bud get to operate its six programs (Stationary Sources, Mobile Sources, Indoor Environment, Technical Services, Planning and Policy, Administrative Services). The Division employed 161 people and had a budget of$21.2 million for fiscal year 2 011. Ofthe total budget, 21 percent was derived from federal grants, 31 percent from mobile source fees, 43 percent from stationary source fees, and 5 pe r cent from other cash sources. State Boards Section 128 of the CAA indicates Colorado's State Implementation Plan must contain requirements th a t any board or body which approves permits or enforcement orders under the CAA must have a majority of members who represent the publi . c interest and do not deri ve any significant portion of their income from persons subject to permits or enforcement orders . The Air Quality Control Commission's Procedural Rules, section 1 . 11.0 state that " The Commission shall have at least a majority of members who represent the public interest and do not derive a significant portion of their income from persons subject to permits or enforcement orders under this article or under the federal act. The members of the Commission shall disclose any potential conflicts of interest that arise during their terms of membership to the oth er Commissioners in a public meeting of the Commission." AQCC Procedural Rules, section 1.11.0 were incorporated into Colo rad o's S IP and approved by EPA on Januar y 4, 2012 (77 FR 235).

Re lationships with other agencies responsible for carrying out State activities The Division contracts with local governments in two distinct ways: 1. Colorado grants monies to local health departments to endow thein as agents of the State to provide inspections of some local stationary sources , asbestos abatemen t jobs, and CFC sources . Some local health d epartments also operate gaseous and particulate monito r s under contract for the state. These efforts must comply with federal and state regulations . 2. Colorado grants monies to lo cal governments to help pay for their support of SIP el ements via pub li c and private partnerships, education and informational campaigns. Most of these

ag enc ies create their own work plan that consists of programs they believe will help enhance air quality in their communities in accordance with general SIP directives.

Colorado has adopted specific regulations for local attainment/maintenance areas to assure these areas meet requirements of the state SIP. These regulations include The Colorado Air Quality Control Commission SIP-specific regulations, 5 CCR 1001-20. These regulations provide the necessary authority for the Division to adequately enforce the provisions of the SIP elements in local attainment/maintenance areas . In addition, Colorado retains its full a u thority and responsibility to enforce the SIP and the Co l orado Po ll ution Prevention and Control Act in l ocal jurisdictions under the local government provisions of 25-7-128, C.R.S . Clean Air Act Section 110 (a)(2)(F) - Stationary Source Monitoring and Reporting Colorado Air Quality Control Commission Regulations 1 , 3, and 7, as well as the Common Provisions Regulation , address the issue of stationary source monitoring. - 6 - Colorado 1 10 SIP Elements - 2 0 08 Le ad NAAQS July 26 , 2012Colorado Regulation 

### 1sets forth emissionlimitations, equipmentrequirements and workpractices (abatement and control measures) intended to control the emissions ofparticulates, smoke, and sulfur dioxides from newand existing stationary sources. An

### AirPollutant Emission Programis required inthe Colorado Pollution Prevention and Control Act Section 25-7-114.1, C.R.S. APEN requirements are further defined 

### inRegulation 3,which requires stationary sources to report their emissions on a regular basis through APENs. These requirements are found inRegulation 3, PartA, Section II, 

### "AirPollutant EmissionNotice Requirements." Regulation 3 also requires stationary sources to monitor their emissions under certain conditions. PartA. Section Villrequires monitoring performed in accordance withEPA accepted procedures, andrecord keeping ofairpollutants. Regulation 3 also provides for a pennittingprogram that establishes emission limitations and standards.Emissions mustbe reported by sources tothe state for correlationwith applicable emissions limitations and standards. Monitoring maybe required for bothconstruction and operating permits. Regulation 7 includes requirements for owners and operators ofVOC sources to conduct monitoring, keep records, and report results tothe Division. The CommonProvisions Regulation mayrequire owners and operators ofstationary airpollution sources to install, maintain, anduseinstrumentationto monitor andrecord eniission data as a basis for periodic reports to the Division. 

### Section 110 (a)(2)(G) - Emergency Power The Statehas the authority to implementemergency powers similar to Section 303 ofthe Clean Air Act
. First, the EPA-approved "DenverEmergency Episode Plan" (74 FR 47888) addresses ozone, particulate matter , and carbon monoxide for the Denvermetro region andrequires the State to implementprotective measures when airquality exceeds definedthresholds. Additionally, the Colorado Pollution Prevention and Control Act, Sections 25-7-1 12 and 25-7-113, C.R.S. generally describe Colorado's authority regarding air pollution emer ge ncies for any 

### air pollutants endangering public health, welfare orthe environment anywhere inthe state. These sections provide authority comparable to CAA Section 303. The Colorado act allows the Divisionto issue a cease-and-desist order ifconditions warrant, andto apply for a restraining order orinjunction in distric t court. Sections 25-7-112 and 113, C.R.S. also allowth e Governorto declare a state ofair pollution emerge ncy andtake any and 

### all actions necessary toprotectthe health of thepublic. As described inEPA's September 25, 2009 guidance, areas thathave had a PM2.5 exceedance greater than 140.4 ug/m3 should have an emergency episode plan. 

### Ifno suchconcentrationwas recorded since 2006, the state canrely onits ge . neral emergency authorities. Colorado has never recorded such a PM2.5level and thus an emergency ep isodeplanfor PM2.5 is not necessary.

- 7

- Colorado 110 SIP Elem ents
- 2008 L ead NAAQS J uly 26 , 20 1 2Nevertheless, the State hereby certifies that it has the appropriate emergency powers to address PM2.5 epi s odes , as described above. Additionally, the State implements EPA ' s air quality index system and typically issues alerts and advisories to the public when any p ollut ant is expect ed to or exceeds an AQI index value of 100. If

pollutant concentrations are expected to or actually exceed EPA's recommended index value thresholds of201 (alert), 301 (warning), 350.5 (significant harm), or 401 (emergency), the State can invoke emergency powers. Section 110 (a)(2)(H)- Provisions for SIP Revisions Due to NAAQS Changes or Fin d i ng s of Inadequacies The State of Colorado has the ability and authority to address and revise the State Implementation Plan due to changes in the NAAQS or due to findings of inadequacies. The Colorado Air Quality Control Commission has the authority and the duty to adopt and revise a State Implementation Plan as necessary to comply with the federal requirements . Colorado Air Pollution Prevention and Control Act, Section 25-7-105 (l)(a)(I), C.R.S . directs the Colorado Air

Quality Control Commis s ion to promulgate rules and regulations as r elated to a comprehensive SIP

which will assure attainment and maintenance of the NAAQS and which will prevent significant deterioration of air quality in the State of Colorado. The Colorado Act states that the comprehensive SIP shall meet all req u irements of the federal act and shall be revised w h enever necessary or appropriate. Colorado Air Pollution Prevention and Control Act Section , 25-7-109, C.RS. al s o gives the Colorado Air Quality Control Commission the authority to promulgate emission control regulations.

Section 110 (a)(2)ffi- Provision s for Nonattainment Areas to M eet the Applicabl e Requirements of Part D While the E PA 110 SIP guidance ofboth October 2, 2007, and October 14, 2011, excludes the

need for determinations under Part I, Colorado meets the applicable requirements for SIPS and

SIP revi s ions in nonattainrnent areas under the Colorado Air Quality Control Commission's Regulation 3, Part D, as explained above. Section 110 · (a)( 2)(J)
- Cons ult a tion with government officials, Public Notifica tion,

Preve ntion of Si gnific ant Deterioration **of~** Qualitv and Visibility Protection Consu ltation wi th Government Officials The Colorado Air Pollution Prevention and Contro l Act 25-7-105(1)(d), C.R.S. requires a satisfactory process of consultation with general purpose local governments and any federal land manager having authority over federal land to which th e state implementation plan applies, pertaining to transportation controls, air quality maintenance plan requirements, preconstruction review of stationary sources of air pollution, or any measure referred to in the PSD or the NNSR permitting programs, or granting de l ayed compliance orders pursuan t to Section 25-7-1 18 , C.R.S. - 8 - Colorado 110 S IP Element s - 2008 Lead NAAQS Jul y 26 , 2012Colorado's Transportation Conformity Rule, Regulation 10, Part

### ill, specifies indetailthe process for interagency consultation relatedtotransportation confonnity in SIP planning. Therule sets out theminimum requirements androles and responsibilities for interagency consultation (Federal, State, regional and local) and resolution ofconflicts. Consultation requirements are also detailed inChapters 2 and 10 ofColorado's Regional Haze SIP. Thechapters specifythe consultationprocess with federal landmanagers, tribes and other states, bothduring
. the development ofthe plan and in future commitments under theplan. Local government coordination and consultation is also described 

### in25

-7

- 128, C.R.S. which covers local government's authority to enact 

### airpollution resolutions orordinances, standards and regulations, their submission and enforceability as part ofthe SIP, andthe coordination of

### air pollution plans andprograms between the state and local governments. Engineering and meteorological consultation is provided bythe State to local agencies. The Sta te assists local agencies inplanning 

### air management programs for their respective areas. The Colorado 

### Air Quality Control Commissionholds public meetings and hearings on all SIP revisions in accordance withthe 

### Air Quality Control Commission Procedural Rules. Public comment is solicited and accepted atColorado 

### Air Quality Control Commission meetings and hearings. Public Notification Colorado notifies the public ofinstances orofareas inwhich anynational primary**amb~ent** 

### air quality standard is exceeded through the website and public announcements. Included inthis notification are public awareness announcements regarding health hazards and manners in which thepublic can participate inregulatory and other efforts to improve Colorado's 

### air quality. Not only does the State provide after

-the-fact information about readings inexcess oftheNAAQS,the Denver PM10 SIP provides for advance warnings to the public that the NAAQS maybe exceeded whenever meteorological conditions make itpossible or likely for ambient concentrations to exceed theNAAQS. The 

### Air Quality Control Commission also issues an annual Reportto the Public, aspartofits duties · under 25

-7-105, C.R.S. which notifies the public ofareas ofNAAQS exceedances statewide, associated health hazards, and howthe public canparticipate inregulatory and other efforts to improve 

### air quality. The Report to the Public is distributed through the Commission's mailing list and posted onthe Commission'spublic website
. The Divisionprepares a daily public notification inthe form ofan 

### AirPollutionAdvisory for a nine-county Denver-Boulder metropolitan and NorthFront Range area and the communities of Grand Junction, Fort Collins, Greeley and Colorado Springs. The advisory is posted onthe Division website andincludes details ofthe day's air quality and visibility, a forecast ofthe coming day's 

### air quality, residential burningrestrictions and voluntary motor vehicle driving reduction requests during the winter high poll ution season. The advisory includes links to an openburning forecast and other important information such as the day's Air Quality Index, the healtheffects ofspecific pollutants andmeasures that canbe taken by the publicto reduce exposure. While notpart ofColorado's SIP, the advisories are part ofan ongoing commitment bythe State to inform and educate citizens
. about 

### air quality. - 9 - Colorado 110 SIP Elements

- 2008 Lead NAAQS Jul y 26 , 2012In addition to the daily Front Range and Grand Junction air quality forecasts , the state has expanded its fo r ecasting and notifi c a t ion abilities statewi d e . The state ' utilizes data from monitors throughout Colorado and will issue a health advisory if monitors show, or are expected to show, an exceedance of air quality standards. The state issues statewide smoke and blowing dust advisories when conditions show that such an event is imminent or in process. The advisories include public notification and education elements ,

and inform the public about actions to take during imminent blowing dust and wildfire events that could lead to high levels of particulate matter.

The smoke and blowing dust advisories may be issued as part of EPA-approved Natural Events Action Plans that have been developed for Lamar and Alamosa, and for wildfires. The advisories may also be issued independently of such Natural Events Action Plans for communities not covered by the plans. Other Colorado communities also maintain and operate daily air quality forecasts, including Mesa County on the Western Slope and El Paso County in the Colorado Springs area . Prev ention o f Significant Det er i ora ti o n of Air Q u a li ty a n d Vis i bility P r otection Prevention of Significant Deterioration

Colorado Air Quality Control Commission Regulation 3 (Stationary Source Permitting ' and Air Pollution Emission Notice Requirements), Regulation 6 (Standards of Performance for New Stationary Sources) and Colorado's Long Term Strategy for Visibility Protection adequately address Prevention of Significant Deterioration and Visibility Protection. For example, new major stationary sources or major modifications are restricted in their emissions in order to protect the PSD increment under Co l orado Air Quality Control Commiss i on Regulation 3. PSD and visibility analyses are also required by NSR r e gulations of Colorado . Colorado is required to review new major stationary sources and major modifications prior to construction to assess potential inipacts on visibility in any Class I Area. Colorado Air Quality Control Commis s ion Regulation 3 . XLE, ''New Source Review " (Appendix D) describe s the applicant's demonstration that the proposed source will not have an adverse effect on visibility in Class I Areas. Visibility Colorado relies on its Regional Haze SIP to protect visibility. T h e Regional Haze SIP r eceived initial approval from the U.S. EPA on March 8, 2012, with the notice of proposed approval published on March 26, 2012 (77 FR 18052). In addition, The Interstate Transport SIP submitted to EPA on March 31,2010 and approved by

E PA ( 77 FR 1027 , 75 FR 31306 , 76 FR 22036), demonstrates that there is a significant downward trend in Colorado's visibility impairing emiss i ons, visibility in surrounding Mandatory Class I Areas is improving over time, and regional modeling indicates that Colorado has an extremely small contribution to out-of - state haze. Thus, air pollution sources an d other types of emission activity within the State of Colorado do not interfere with measures r equired to be included in the applicable implementation plan of another state t o protect visibility. - 10 - Colorado 1 10 SI P Elements - 2 008 Lead NAAQS July 26 , 2012Clean 

### Air ActSection 110 (a)(2)(K) - 

### Air Quality Modeling and Data Handling 

### Colorado bas the authority andresources to model for all 

### criteriapollutants. Air

### quality modeling is done for SIP revisions and for transportation conformity. Colorado Air 

### Quality Control Commission Regulation 3 (Stationary Source Permitting and Air

### Pollution Emission Notice Requirements) requires stationary sources to predictthe effect ofair 

### pollutants in attainment areas. Regulation 3 also details the State ofColorado's programregarding permitting as related to air 

### quality modeling and datahandlin g inpredicting the effect ofemissions ofapollutant with an established NAAQS. Regulation 3Part A, Section Vlli 

### "Technical Modeling and Monitoring Requirements" states that all 

### estimates ofambient concentrations required under Regulation 3 shall be based onthe applicable air 

### qualitymodels, databases, and otherrequirements generally approved byEPA and specifically approved by the Division
. Part A also requires all modeling dataused to determine compliance to be appropriate giventhe topography, meteorology and other characteristics of the region. The Modeling, Meteorology, and Emission InventoryUnit withinthe Divisionperforms and reviews air 

### quality impact analyses for a variety ofprograms, including state implementationplan revisions,transportation conformity determination, stationary sour cepermitting, environmental impact statements, and hazardous waste site studies. The analyses include modeling, meteorological analysis, and emission inventory development for mobile sources and area stationary sources such as woodburning. The unit also performs air 

### quality forecasting for the Denver-area High Pollution Season, open burning, and for special air 

### quality studies. Additional information regarding these programs and authority is provided below. Some ofthese programs are found 

### in the SIP
.For example, both Colorado Air 

### Quality Control Commission Regulation 4 (Woodburning) and the Denver PM10 SIP address State air 

### qualitymod elingprograms. PSD and.IncrementConsumption

- Colorado's PSD program includes a requirementthat the State periodically assess the adequacy ofit s planto prevent significant deterioration ofair 

### quality. This is presented in Regulation 3, PartD, Section X.A.4. Part D also requires major sources to conduct ali 

### quality impact analyses for PSD increment consumption and for compliance withNAAQS. Part D also requires analysis ofthe impairmentto visibility, water, soils, and vegetation that would occur as a resUlt ofthe emissions ofa regulated pollutantin significant amounts and general commercial, residential, industrial, and other growth associated with the source ormodification. SIP Development

- Modeling is performed inthe development andrevision ofState Implementation

**P~ans,** 

### as needed orpresc ribed by the U.S. EPA, to ensure that specific areas ofthe state will maintain orre-attain compliance withtheNAAQS in light ofdevelopment and increased population and traffic. Permits

- The primary Colorado regulation for air 

### quality permits is 

### Colorado 

### AirQuality Control Commission RegulationNo
. 3. Certain new /modified air 

### pollution sources are subjectto the regulatory modeling requirements in Regulation 3
.Regulation 3, Part A, subsection VIII describes Colorado's technical modeling and monitoring requirements
. Modeling is often required to obtain a construction permit.

- 11
- Colorado 1 10 SI P El ements - 2008 L ead NAAQS July 26, 2012The state submits data to the U.S. EPA as required under Regulation No.3, Part D, Section VI. C . requiring the Division to transmit to the Administrator of the U. S. EPA a copy of each permit application relating to a major stationary source or major modification subject to this regulation, and provide notice of every action related to the consideration of such permit. Clean Air Act Section 110 (a)(2)(L) - Permitting Fees The State of Colorado requires the owner or operator of a major stationary source to pay the Division any fee necessary to cover the reasonable costs of reviewing and acting upon any permit application. The collection of fees is described in Colorado Air Quality Control Commission Regulation 3. Specifically, Regulation 3, Part A. Section VI describes that each applicant required to obtain a permit must pay a fee, including the cost of permit review and relevant actions and that stationary source owners or operators must pay an annual fee based on total emissions. The funds are used by the State to administer programs for the control of air po ll ution from stationary sources. Clean Air Act Section 110 (a)(2)(M)- Consultation/Participation by Affected Local Entities The Colorado Air Pollution Prevention . and Control Act 25-7-105(1)(d), C.R.S. requires a satisfactory process of consultation with general purpose local governments and any federal land manager having authority over federal land to which the state implementation plan applies, pertaining to transportation controls, air quality maintenance plan requirements, preconstruction review of stationary sources of air pollution, or any measure referred to in the PSD or the NNSR permitting programs , or granting delayed compliance orders pursuant to Section 25-7-118, C.R.S.

Colorado Air Quality Control Commission Regulation 3 provides for consultation and participation by local entities. Local governments receive notice and have the opportunity to comment on and participate in construction permit review procedures and operating permit application procedure s under the provisions of Reg. 3, Part D. Section IV .A.l., "Public Comment Requirements." Local government coordination and consultation is also described in 25-7-128, C.R.S. which covers local gov e rnment ' s authority to enact air pollution re s olutions or ordinances, standards and regulations, their submission and enforceability as part of the SIP, and the coordination of air pollution plans and programs between the state and local governments. Colorado Air Quality Control Commission Regulation 10, "Transportation Conformity," defines the criteria the Colorado Air Quality Control Commission uses for transportation conformity determinations to develop SIP revisions in non-attainment areas. Interagency consultation

requirements are detailed in Reg. 10, and meet the federal requirements under 40 CFR 51.390 , as published on August 15, 1997 ( 62 FR 158). The Colorado Air Quality Control Commission holds a pubtic hearing before adopting any regulatory revisions to the SIP. Local political subdivisions may participate in the hearing. The requirements for public hearings , including public notice of hearings, are established in 25-7-110, C.R.S. that describes the procedures to be followed in setting standards and regulation s . - 12 - Colorado 110 SIP Ele m ents - 2008 Le ad NAAQS Jul y 26 , 2012

### AP PE NDIX Lead Inventory for Colorado 

### The table onthe following page shows lead inventory for Colorado for all stationary sources withlead emissions. The inventory was derived from 2011 Colorado 

### AirPollutant Emission Inventory Data. No sources are-located within two miles from the state border, and no sources emit more than 0.5 tons per year oflead, which are th
. e criteria ofconcern for interstate transport that the U.S. EPA cites inthe October 14, 2011 "Guidance onInfrastructure State Implementation Plan (SIP)**El~ments** 

### Required Under Sections 110(a)(l) and 110(a)(2) for the 2008 Lead (Pb) National Ambient 

## Air Quality Standards (NAAQS)." This 2011 inventory shows significant reductions in lead emissions from what were presented 

### in Colorado's September 17, 2009 "Technical Support Document for Lead Attainment in Colorado: Eight-Factor Analysis
." That document contained 2008 inventory of2.7 tons peryear statewide, with no sourceemitting more than 0
.5 tons peryear or located within two miles ofthe state border. The 2009 Technical Support Document also contained monitoring datathat showed Colorado's ambient air

### concentrations ofleadwere well below th e National Ambient Air Quality Standards, andprovided the basis for the state's reconuriendation that all areas in Colorado should be classified as attainment orattainment/unclassifiable for lead
.



### -. •

- 1 3 - Colorado 11 0 SIP El ements
- 2008 Lead NAAQS July 26, 2012I !

- - - - - - -· -. ' Colorado Stationary Source 2011 Air Pollutant Emission Inventory for Lead ·' f ·- ' . ; . - ' . City N a me Facility Name -. : : ·' ..... ,.- - -· **-~** '- - 1 PUEBLO AHEA CF & I STEELLP 2 FORT LUPTON GOLDEN ALUMINUM CO . 3 DENVER SERCK SVCS DBA DENVER RADIATOR & SHUTTER 4 TRINIDAD 252 MI. NE OF USARMY HQ FT CARSON 4TH INF MEG PCMS 5 FORT MORGAN AREA WESTERN SUGAR CO 6 PUEBLO COLO MENTAL HEALTH INSTITUTE AT PUEBLO 7 SHER IDAN WESTERN METALS RECYCLING 8 AURORA lvliKRON ASSEMBLY TECHNOLOGY 9 GOLDEN COLORADO-GOLDEN ENERGY CORPORATION 10 CRAIG 2 .9 MI. SW OF TRISTATE GENERATION CRAIG 11 STERLING CLEAN HARBORS 12 FLORENCE 3 . 8 MI. E OF HOLCIM (US} INC . PORTLAND PLANT 13 PUEBLO 4 . 5 MI. S OF GCC RIO GRANDE - PUEBLO CEMENT PLANT 14 COMMERCE CITY DENVER TRUCK & TRAILER 15 '/tlHEAT RIDGE ROCKY MOUNTAIN BOTILE CO 16 GOLDEN COLORADO-GOLDEN ENERGY CORPORATION 17 CRAIG 2.9 MI. SW OF TRISTATE GENERATION CRAIG 18 PUEBLO AREA DAVIS WIRE PUEBLO CORP .

1 9 PUEBLOAHEA DAVIS VVIRE PUEBLO CORP. 20 LONGMON T AREA WESTERN FOUNDRIES 21 CRAIG 2.9 MI. SW OF TRISTATE GENERATION CRAIG 22 LYONS CEMEX CONSTRUCTION MATERIALS- LYONS 23 COLORADO SPRINGS PETERSON AFB 21 CES CEV 24 FOUNTAIN AREA COLORADO SPRINGS UTILITIES- NIXON PL T 25 LONGMONT AREA WESTERN FOUNDRIES 26 GOLDEN COLORADO-GOLDEN ENERGY CORPORATION 27 SECURITY SCHLAGE LOCK CO LLC- IR SECURITY TECH 28 COLORADO SPR I NGS COLORADO SPRINGS UTILITIES-DRAKE PL T 29 NUCLA 2 . 3 M I. SE OF TRISTA TE GENERATION NUCLA 30 COLORADO SPRINGS COLORADO SPR IN GS UTILIT I ES-DRAKE PL T

3 1 COLORADO SPRINGS COLORADO SPR IN GS UTILIT I ES-DRAKE PL T 32 DENVER POWER ENGIN EERING 33 LYONS CEME.X CONSTRUCTION MATERIALS- LYONS 34 LONGMONT AHEA WESTE R N FOUNDRIES 35 DENVER BRITE LINE TECHNOLOGIES INC 36 **KERS~** 4.3 ML S OF 8-.JSIGN WEI L SERVICES Tota l: - 14 - Colorado 110 SI · P Elements - 2008 Lead NAAQS July 26 , 2012

Actual Emission ' Estim a te [tons/year) 0 .38 4500

0 . 320100 0 . 098250 0 . 087500 0 . 087141 0 . 066633 0 . 059976 0 . 055 1 45 0 . 033000 0 . 029450 0 . 028550 D . 023400 0 . 023000 0.021500 0 . 020000 0 . 017500 0 . 015500 0.01550 0 0 . 01550 0 0 . 014800 0.014500 0 . 007 115 0.004540 0 . 004150 0 . 004000 0 . 002500 0 . 00 1 850 0 . 001800 0 . 00 1 500 0 . 00 1 150 0 . 001000 0 . 000763 0 . 000425 0 . 000250 0.000052 0 . 000001 1.46254

'''"'' Actual Emission Estimate (lbs/year] 769 . 0 640 . 2 196 . 5 175 . 0 174 . 3 133 . 3 120 .0 110 . 3 66 . 0 58.9 57 . 1 46.8 46 . 0 43.0 40 . 0 35 . 0 31 . 0 31.0 31 . 0 29.6 29 . 0 14 . 2 9 . 1 8 . 3 8 . 0 5 . 0 3 . 7 3 . 6 3.0 2 . 3 2 .0 1 . 5 0 . 9 0.5 0.1 0 . 0 2 ,925.1 •