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'SE'

December 21, 2012

MEMORANDUM

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

Nonattainment Area

FROM: Jeff Hunt, PM2,5 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 TOXICS
public 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.