Docket: **EPA-R10-OAR-2014-0744**

**WA Infrastructure SIP for 1997, 2006, and 2012 PM2.5 NAAQS**

Comment On: **EPA-R10-OAR-2014-0744-0008 Air Quality State Implementation Plans; Approvals and Promulgations: Washingt**  **on; Infrastructure Requirements for the Fine Particulate Matter National A**  **mbient Air Quality Standards** 

Document: **EPA-R10-OAR-2014-0744-0009 Comment on EPA-R10-OAR-2014-0744-0008** 



## Submitter Information

General Comment

**EPA can't approve Washington's section 110(a)(2)(G) submission because WAC 173-435 doe sn't**  **contain any significant harm levels appropriate for PM2.5. Without significant harm levels for**  **PM2.5 for each episode stage (alert, warning, and emergency) the Director of Ecology isn't legally**  **allowed to declare any stage of an emergency episode. According to WAC 173-435-050(1) "Whenever applicable criteria are met, the director may declare and termi**  **nate the forecast, alert, and warning stages of an episode." Meaning that the director can only declare a stage of an**  **emergency episode 'whenever applicable criteria are met' which are spec ifically identified in 173-**  **435-030.**

**Also, the sampling sites, equipment, and methods in 173-435-070 were written in 1977 (filed in 1989) with PM10 in mind (at that time it was commonly held that Lead was considered part of**  **PM10). Since then the NAAQS criteria pollutants and their criteria levels have been updated but**  **WA hasn't updated these regulations since 1989 (and it's unclear whether the regulations were**  **updated in 1989 from the original 1977 regulations) to reflect the addition of the PM2.5 NAAQS and the PM2.5 and Lead monitoring methods, equipment, and sampling sites.** 

**EPA can't simply rely on the fact that the governor of WA is able to declare an emergency stage**  **whenever he/she feels like it. As with all other criteria pollutants Washingt on should specify (and**  **EPA should require) significant harm levels for PM2.5 for each episode stage (alert , warning, and**  **emergency). These regulations should be updated to reflect the current NAAQS pollutants**  **(including Lead and PM2.5) and the current NAAQS levels and monitoring, equipment, sampling, and citing requirements. Without a significant harm level for PM2.5, only the governor is legal**  **ly** 

# PUBLIC SUBMISSION As of: **11/14/14 2:50 PM** Received: **October 22, 2014** Status: **Posted** Posted: **November 12, 2014** Tracking No. **1jy-8f24-2lml** Comments Due: **November 17, 2014** Submission Type: **Web Page**  **1 of**  **2**

**11/ 14/**  **2014 https://www.fdms.gov/fdms/getcontent?objectId=09000064818e773b&format=xml&sho** 

**... allowed to declare an episode stage with respect to PM2.5, and even then the governor can only** 

**declare an emergency stage (no alert or warning stage). Since Ecology can't legally de clare an**  **alert, warning, or emergency stage, and the governor is only able to declare an emergency st age,**  **this means that for all intents and purposes there can never legally be an alert or warning stage for**  **PM2.5. Even if the governor declares an emergency stage for PM2.5, Ecology has no criteria on which to base "termination" or 'downgrading' the stage as required by 173-435-030(5), which**  **requires the use of the criteria in 173-435-030(1, 2, 3, and 4). This severely limits the ability of the**  **Department of Ecology to protect the health and safety of the citizens of Washington St ate, unless**  **of course the air pollution becomes so bad that the governor is able to do something. The emergency episode regulation should give Ecology the legal authority to declare emergency**  **episode stages based on criteria for PM2.5 and Lead, and should be required to use current monitoring and sampling methods. Therfore EPA can't approve 110(a)(2)(G) since the eme**  **rgency episode regulation doen't include significant harm levels for PM2.5 or Lead nor**  **modeling/sampling requirements for PM2.5 and Lead. Page**  **2 of**  **2**

**11/ 14/**  **2014 https://www.fdms.gov/fdms/getcontent?objectId=09000064818e773b&format=xml&sho** 

**...**