00,OSrgTe,s UNITED STATES ENVIRONMENTAL PROTECTION AGENCY yo REGION 10 W 1200 Sixth Avenue, Suite 900 

### 'Vr/ Seattle, WA 98101-3140
49, AL PRO'S E' December 21, 2012

MEMORANDUM
SUBJECT: Final Review: State Implementation Plan Revision, Tacoma-Pierce County

Nonattainment Area
FROM: Jeff Hunt, PM 2,5 Lead
THRU: Alexander Fidis, Office of Regional Counsel
TO: Debra Suzuki, Unit Manager

Air Programs Unit The final version of the State Implementation Plan (SIP) revision submitted by the Department of Ecology (Ecology) on November 28, 2012 contains two elements for EPA approval. Appendix A contains the "2008 Baseline Emissions Inventory and Documentation." Appendix B contains the "SIP Strengthening Rules." The submittal also contains other appendices and background information intended to support the information contained in Appendices A and B. Since the Tacoma-Pierce County nonattainment area is one of our highest priorities, EPA staff worked closely with Ecology and Puget Sound Clean Air Agency (PSCAA) in the development of a technically sound submission. Included in the docket for this action is a September 19, 2012 letter from Richard Albright, Director of the Region 10 Office of Air, Waste, and Toxics, describing EPA's review of the draft 2008 baseline emissions inventory. In this letter EPA stated, "Based on our pre-submittal review, we believe the version provided to us on September 10, 2012 would satisfy the emission inventory requirements of 40 CFR 51.1008 assuming there are no substantive changes to the final version or issues that arise during the state public comment period. The EPA will make a final decision based on its review of the complete State Implementation Plan that is submitted following your public process and after consideration of any comments we receive as part of EPA's public process." I reviewed the final version and confirmed that there were no substantive changes since the version we last reviewed. I also reviewed the public comments contained in Appendix G and found no issues related to the 2008 emissions inventory. Therefore, I recommend that EPA propose approval of Appendix A, "2008 Baseline Emissions Inventory and Documentation" into the SIP. Similarly, EPA staff worked closely with PSCAA in reviewing proposed changes to Regulation I Article 13: Solid Fuel Burning Device Standards to ensure they would meet Clean Air Act requirements. Included in the docket is an August 22, 2012 letter containing EPA's comprehensive review of the proposed changes with the determination that, "Based on current EPA policy and requirements, we believe these rule revisions would be approvable into the State Implementation Plan if submitted without significant changes. EPA will make a final decision based on its' review of the complete State Implementation Plan that is submitted following your OFFICE OF AR. WASTE. AND TOXICSpublic process and after consideration of any comments we receive as part of EPA's public

process. I reviewed Appendix B, "SIP Strengthening Rules" which contains the final changes to Regulation I -.Article 13: Solid Fuel. Burning Device Standards, adopted by the PSCAA Board on October 25, 2012. In my final review I confirmed that PSCAA made no substantive changes to the rules since the version EPA reviewed in August. I also reviewed the response to comments from both the Ecology and PSCAA public comment periods, The comments fell in two general categories: 1.) those opposed to stronger regulation of wood smoke, and 2.) those who suggested additional regulatory and enforcement measures related to wood smoke. After considering all the comments received, I believe both Ecology and PSCAA adequately responded to the issues raised and I recommend that EPA propose approval of Appendix B, "SIP Strengthening Rules" into the SIP.