North Carolina Department of Environment and Natural Resources 

Division of Air Quality 

Michael F. Easley, Governor William G. Ross, Jr., Secretary 

0. Keith Overcash, P.E., Director 

December 12.2007 

Mr. J.I. Palmer, Jr. 

Regional Administrator 

U.S. Environmental Protection Agency, Region 4 

Atlanta Federal Center 

61 Forsyth Street, SW 

Atlanta, Georgia 30303-8909 

Subject: Section 110(a)(l) and (2) State Implementation Plan (SIP) Requirements for 8-hour 

Ozone 

Dear Mr. Palmer: 

This letter addresses the North Carolina Department of Environment and Natural 

Resources, Division of Air Quality's (NCDAQ) efforts to meet the requirements of Section 

110(a)(l) and (2) SIP Requirements for 8-hour Ozone. In particular, this letter responds to the 

October 2,2007, memorandum, "Guidance on SIP Elements Required Under Sections 110(a)(l) 

and (2) for the 1997 8-hour Ozone and PM2.5 National Ambient Air Quality Standards." 

NCDAQ believes it has addressed all of the required elements listed in Attachment A of 

the October 2,2007, guidance memorandum with the exceptions of Section 1 lO(a)(2)(D)(i) - 

interstate transport, and Section 110(a)(2)(J) - prevention of significant deterioration (PSD) and 

visibility protection. 

With regard to Section 1 lO(a)(2)(D)(i), NCDAQ submitted a letter dated May 25, 2007 

outlining how those requirements would be met. Per USEPA instructions, NCDAQ noticed this 

letter for public comment on or before October 6, 2007, such that the letter could be incorporated 

into the SF. The public comment period ended on November 6,2007 and no comments were 

received. The official SIP submittal is attached to this letter as Attachment A. 

With regard to Section 110(a)(2)(J), NCDAQ's deficiency is that NCDAQ's rules do not 

acknowledge NOx as a precursor to ozone. However, NCDAQ has treated NOx as a precursor to 

ozone during the permitting process since 1995 after a 1994 study on ozone formation in Atlanta 

by the Georgia Institute of Technology concluded that NOx was the primary ozone precursor in 

Atlanta and much of the Southeast. NCDAQ has addressed this deficiency with a rule amendment 

that includes reference to definitions in 40 CFR 5 1.166. This rule amendment was taken to public 

hearing on November 7,2007 and is open for public comment until December 14,2007. NCDAQ 

expects the rule amendment to become State effective in March 2008. Attachment B is a copy of 

the amended rules. 

1641 Mail Sewice Center, Raleigh, North Camlina 27699-1641 

2728 Capital Blvd., Raleigh, North Camlina 27604 

Phone: 919.715-76701 FAX 919-715-7476 I Internet: w.ncair.org 

An Equal OpportunityiAffimative Action Empioyer - 50% RecycledMO% Post Consumer Paper 

One NorthCarolina 
Mr. 3.1. Palmer, 31. 

12/12/07 

Page 2 

NCDAQ believes it has in good faith addressed the requirements of Section 1 lO(a)(l) and (2) 

through the various SIP submittals. 

Please contact Laura Boothe of my staff at (919) 733-1488 if you have questions regarding 

this letter. I look forward to working with you as we implement programs to address the 8-hour 

ozone SIP requirements. 

Sincerely, A 

Enclosures 

cc: Kay Prince 

Brock Nicholson 

Laura Boothe