# Was hington State Implementation Plan Revision

Interstate Transport of Lead

, Nitrogen

Dioxide , and Ground

- Level Ozone

March 20 15

Public ation no: 15-02-005

# Publication and Contact Information

Th is r eport is a vailable on th e D epartment of Ecol ogy’s w ebsite a t

h ttps://fortress.wa.gov/e cy/publications/SummaryPages/1502005.html

For more information contact:

D epartment of Ecology Attn: Air Quality Program

P.O. Box 47600 Olympia, WA 98504-7600

Phone: (360) 407.6800

W ashington State Department of Ecology

- www.ecy.wa.gov

o Headquarters, Olympia 360-407-6000

o Northwest Regional Office, Bellevue 425-649-7000

o Southwest Regional Office, Olympia 360-407-6300

o Central Regional Office, Yakima 509-575-2490

o Eastern Regional Offic e, Spokane 509-329-3400

I f you need this document in a format for the visually impaired, call the Air Quality Program at

360-407-6800. Persons with hearing loss can call 711 for Washington Relay Service. Persons with a speech disability can call 877-833-6341.

# Interstate Transport of Lead
, Nitrogen

Dioxide , and Ozone

Addressing requirements for the 2008 Lead

, 2010 Nitrogen Dioxide , and 2008 Ozone National Ambient Air Quality Standards

by

Air Quality Washington State Department of Ecology Olympia, Washington

# Table of Contents

Page

List of Figures and Tables

................................ ................................ ................................ ... ii Figures

................................ ................................ ................................ ........................... ii

Tables

................................ ................................ ................................ ............................ ii

Acknowledgements

................................ ................................ ................................ ............ iii

Executive Summary

................................ ................................ ................................ ........... iv

Introduction

................................ ................................ ................................ .......................... 1

Interstate Transport of Lead

................................ ................................ ................................ . 3

Back ground

................................ ................................ ................................ .................... 3 Washington’s approach

................................ ................................ ................................ .. 4 Transport Assessment

................................ ................................ ................................ .... 5

Interstate Transport of Nitrogen Dioxide

................................ ................................ ............. 7 Background

................................ ................................ ................................ .................... 7 Washington’s approach

................................ ................................ ................................ .. 7 Transport Assessment

................................ ................................ ................................ .... 9 Emissions Inventory

................................ ................................ .............................. 9 Air Quality Data and Design Values for neighboring states

............................... 11

Interstate Transport of Ozone

................................ ................................ ............................ 12

Ba ckground

................................ ................................ ................................ .................. 12 Washington’s approach

................................ ................................ ................................ 13 Transport Assessment

................................ ................................ ................................ .. 13

Appendix.

................................ ................................ ................................ ........................... 14

A. Additional informat ion on Interstate Transport of Lead

................................ ..... 14

B. EPA 2015 “Good Neighbor” Memorandum

................................ ....................... 21

i

# List of Figures and Tables

Page



# Figures

Figure 1 Location of lead sources greater than 0.5 tpy in Washington

................................ .......... 5 Figure 2 Lead sources greater than 0.1 tpy and smaller than 0.5 tpy

................................ ............. 6 Figure 3 Ambient air monitoring levels and emission estimates for the main categories contributing to NOx in Washington

................................ ................................ .............................. 10 Figure A 1 Lead sources (<0.5 tpy) in all bordering counties.

................................ ..................... 14 Figure A 2 Available daily mean values of lead at the Multnomah monitoring site

.................... 20



# Tables

Table 1 Sources greater tha n 0.5 tpy in Washington

................................ ................................ ...... 5 Table 2 2011 Washington State NOx Emissions Inventory of anthropogenic sources

.................. 9 Table 3 Oregon monitoring site measuring NO 2



### ................................ ................................ .......... 11

Table 4 NO 2 

### Design values at the Oregon monitoring site

................................ ........................... 11 Table A 1 List of all lead sources smaller than 0.5 tpy located in bordering counties

................. 15

ii

# Acknowledgements

The authors of this report would like to thank the following people for their contribution to this study:

• Anya Caudill

• Claudia Toro

• Sally Otterson

• Farren Herron

- Thorpe

• Clint Bowman

• Jocelyn Jones

• Amber Littlejohn

• Camille St. Onge

• Joanna Ekrem

• Jeff Hunt

iii

# Executive Summary

The “good neighbor” or “interstate transport” provisions of the Federal Clean Air Act (CAA) protect downwind states from harmful pollution that originates in upwind states. This State Implementation Plan (SIP) revision contains Washingto n’s analysis of the interstate transport of lead (Pb)

, nitrogen dioxide (NO 2 

### ) , and ozone (O 3 

### )

. It finds that Washington’s sources do not significantly contribute to Pb

, NO 2 

### , and O 3 

### air pollution in other states. No new rules are proposed.

Lead is a metal found naturally in the environment as well as in manufactured products. Environmental Protection Agency (EPA) sets standards for lead air pollution because lead exposure can cause health and developmental problems, especially in children. Exposure s to low levels of lead early in life have been linked to effects on IQ, learning, memory, and behavior. Lead persists in the environment and accumulates in soils. Historically, the major sources of

lead were from motor vehicles and industrial sources. Nationwide, lead pollution levels dropped sharply when lead was phased out of gasoline starting in the 1970s. Today, the major sources of lead are lead smelters, ore and metal processers, and piston

- engine aircraft operating on leaded aviation gasoline. There are no large smelters in Washington State. Battery recyclers, wood products facilities, pulp and paper mills, glass manufacturers, refineries and piston

- engine aircraft operating on leaded aviation gasoline are minor sources of lead in Washington.

All areas in Idaho, Oregon, and Washington are in compliance with the lead standard set in 2008. Lead emissions are relatively heavy and do not travel far from the source of emissions. Ecology’s analysis focused on Washington’s sources of lead pollution that are located near state borders with Idaho and Oregon and reviewed existing ambient monitoring data and emissions

inventories. Ecology found no evidence of significant transport of lead pollution across the state

border.

Nitrogen dioxide (NO 2 

### ) is an indicator of the nitrogen oxides (NO

x 

### ) pollution. The main source

of NO

x 

### pollution is the combustion processes. A small percentage of NO

x 

### is directly emitted, but the majority is formed in the atmosphere from a combination of transportation, power plants , off

road equipment, and biomass burning pollution. NO

x 

### exposure has been linked to respiratory effects including airway inflammation in otherwise healthy people and increased respiratory symptoms in people with asthma. Major exposure concerns are local ized along the main traffic

arteries. NO

x 

### reacts with other elements and compounds in the air and contributes in the formation of ground

- level ozone (O 3 

### ) and fine particles. F ine particles interstate transport analysis is separate from this submittal.

A ll areas in Idaho, Oregon, and Washington are in compliance with the NO 2 

### standard set in

2010. Ecology reviewed existing ambient monitoring data, emissions inventories, design values and EPA guidelines to assess transport of NO 2



### . Ecology found no evidenc e of significant NO 2 

### pollution across the state border.

Ground

- level ozone is the primary component of smog. Ground level ozone forms when emissions of nitrogen oxides (NO

x 

### ) and volatile organic compounds (VOCs) “cook” in the sun

— making it mainly a summe rtime pollutant. The major sources of human

- made NO

x 

### and VOCs

iv

### are emissions from industrial facilities, electric utilities, motor vehicle exhaust, gasoline vapors,

and chemical solvents. Ozone pollution can travel over hundreds of miles and can affect bo th

urban and rural areas.

Breathing air containing elevated levels of ozone can reduce lung function and increase respiratory symptoms

. It can a ggravat e asthma or other respiratory conditions. Ozone exposure

also has been associated with increased:

• Vulnerability to respiratory infections

.

• Medication use by people with asthma

.

• Doctors visits

.

• Emergency room visits and h ospital admissions for individuals with respiratory disease

.

Ozone exposure may also contribute to premature death, especially in p eople with heart and lung

disease. In addition, repeated exposure to ozone damages sensitive vegetation and trees, including those in forests and parks, leading to reduced growth and productivity, increased vulnerability to disease and pests, and damaged foliage.

All areas in Idaho, Oregon, and Washington are in compliance with the ozone standard set in

2008. EPA performed photochemical air quality modeling to project ozone concentrations at air quality monitoring sites to 2018

— and to estimate each state ’s contributions to those 2018

concentrations. EPA found that Washington does not contribute significantly to ozone pollution

in other states.

v

# Introduction

Washington State Department of Ecology (Ecology) submits this State Implementation Plan (SIP) revision to address the requirements of the Clean Air Act (CAA) with regard to the 2008 Lead (Pb)

, 2010 1

- hour Nitrogen Dioxide (NO 2 

### ) , and 2008 Ozone (O 3 

### ) National Ambient Air Quality Standards (NAAQS). This revision addresses section 110(a)(2)(D)(i) of the CAA that requires a SIP to:

(D) contain adequate provisions

–

(i) prohibiting, consistent with the provisions of this subchapter, any source or

o ther type of emissions activity within the State from emitting any air pollutant

in amounts which will

–

(I) contribute significantly to nonattainment in, or interfere with maintenance by, any other State with respect to any such national primary or secondary ambient air quality standard....

(II) interfere with measures required to be included in the applicable implementation plan for any other state....to prevent significant deterioration or to protect visibility

The requirements to control interstate transport of pollutants are often referred to as “good neighbor” provisions of the CAA. The intent of the provisions is to ensure that residents and the welfare of downwind states are protected from harmful emissions originating in upwind states. Currently, neither Washington nor its neighboring states (Oregon and Idaho) have nonattainment or maintenance areas with respect to Pb

, NO 2 

### , or O 3



### .

The CAA requires Washington to ensure that any source or type of emissions activity within the state will not contribute signi ficantly to nonattainment or interfere with maintenance in another

state. The Washington SIP, codified in 40 CFR 52 Subpart WW, contains regulations for minor source permitting to ensure protection of all relevant NAAQS 1



### . For major sources, Washington

is already subject to a PSD permitting program operated under an EPA Federal Implementation Plan (FIP).

The analysis developed by Washington in support of this SIP revision show s no indication of a significant Pb or NO 2 

### transport across state borders. EPA’s analysis of ozone transport also

shows that Washington’s sources do not contribute significantly to areas with ozone pollution in

other states. Based on our assessment and findings, we assert that Washington does not contribute significantly to non attainment, or interfere with maintenance, in another state with respect to the Pb

, NO 2 

### , and O 3 

### NAAQS. The information reviewed, findings

, and conclusions are presented in three chapters : the first chapter describes the analysis for the interstate transpo rt

1 Updated revisions to Washington’s SIP “General Regulations for Air Pollution Sources”, Docket ID no. EPA

OAR

- 2014

- 0141 , effective November 3, 2014



### 1

### of Pb

, the second chapter details the findings pertaining to interstate transport of NO 2 

### , and the third chapter reviews EPA’s analysis and findings related to ozone transport

.

2

# Interstate Transport of Lead

Background

Lead (Pb) is a metal found naturally in the environment as well as in manufactured products. Historically, the major sources of lead were fuel combustion from on

- road motor vehicles and

industrial sources. After EPA’s efforts to remove lead from vehicle gasoline, lead emissions from the transportation sector decreased dramatically. Today, the major sources are lead smelters, ore and metal processers and piston

- engine aircraft operating on leaded aviation gasoline. Pb associated with coarse particulate material (PM) deposits to a greater extent near local industrial sources, while fine Pb

- bearing PM can be transported longer distances 2



### .

On October 5, 1978, EPA promulgated primary and secondary NAAQS for Pb. Both were set as

1.5 micrograms per cubic met er ( μg/m 3 

### ) , measured as Pb in total suspended particles (Pb

- TSP), not to be exceeded by the maximum arithmetic mean concentration averaged over a calendar

quarter. The standards were published on the 1977 Air Quality Criteria for Lead , which assessed

the scientific evidence available at the time regarding public health effects as result of exposure

to lead

.

The first review of the Pb standards was initiated in the mid

- 1980s. Based on the scientific assessment, EPA did not propose any revisions to the 197 8 Pb NAAQS. The most recent review was initiated in November, 2004. Based on the assessment findings and considering the significantly different circumstances since Pb was listed in 1976, EPA proposed to revise both primary and secondary standards from 1 .5 μg/m 3 

### to 0.15 μg/m 3 

### , with a rolling three

- month period averaging time and a maximum not to be exceeded over a three

- year period. The final revisions were published in the federal register on November 12, 2008 3



### .

EPA’s revisions were based on the weight of scientific evidence demonstrating neurocognitive

effects of Pb in children. Lead in blood is the most common index of Pb exposure in epidemiologic studies of Pb health effects 4



### . The scientific evidence correlat es levels of Pb in air with levels of Pb in children’s blood, and Pb in children’s blood with IQ loss. The 0.15 μg/m 3


### level was estimated to be protective against air Pb

- related IQ loss in the most susceptible

children 5



### .

On October 14, 2011, EPA issued a Guidance on Infrastructure State Implementation (SIP) Elements Required Under Sections 110(a)(I) and 110(a)(2) for the 2008 Lead (Pb) National Ambient Air Quality Standards (NAAQS)

. As stated in the guidance, EPA believes that

2 See EPA/600/R

- 10/075F, Integrated Science Assessment for Lead

, Section 1.2.1, EPA, ORD, Research Triangle
Park, NC, June 2013

3 73 FR 66964

4 See EPA/600/R

- 10/075F, Integrated Science Assessment for Lead , EPA, ORD, Research Triangle Park, NC, June

2013

5 See Integrated Review Plan for the National Ambient Air Quality Standards for Lead , EPA, November 2011



### 3

### (...) the physical properti es of Pb prevent Pb emissions from experiencing the same travel or formation phenomena as PM 2.5 

### or ozone. More specifically, there is a sharp decrease in Pb concentrations, at least in the coarse fraction, as the distance from a Pb

source increases. Accord ingly, while it may be possible for a source in a state to emit Pb in a location and in quantities that may contribute significantly to nonattainment in, or interfere with maintenance by, any other state, EPA anticipates that this would be a rare

situation , e.g. where large sources are in close proximity to state boundaries.

The Guidance indicates also

(...) requirements of subsection(2)(D)(i)(I) (prongs 1 and 2) could be satisfied through a state’s assessment as to whether or not emissions from Pb sources located in close proximity to their state borders have emissions that impact the neighboring state such that they contribute significantly to nonattainment or interfere with maintenance in that

state.

EPA suggests that sources that emit less than 0.5 ton s per year (tpy) or located more than two
miles from a state border are unlikely to contribute significantly to nonattainment in another

state 6



### .


# Washington’s approach

Ecology reviewed the 2011 National Emissions Inventory (NEI) list of facilities reporti ng lead

emissions and determined their distance from state borders. Subsequently, Ecology assessed the information based on EPA’s suggestion regarding significance of sources either larger than 0.5 tpy or closer than two miles from the border. The inform ation reviewed, findings and conclusions are presented in the next section.

6 See Guidance on Infrastructure State Implementation Plan (SIP) Elements Required Under Sections 110(a)(1) and 110(a)(2) for the 2008 Lead (Pb) National Ambient Air Quality Standards (NAAQS) foot note 7, page 8, September
13, 2013



### 4

# Transport Assessment

The largest sources of lead in Washington are located in King and Snohomish counties. Table 1

lists the largest sources and Figure 1 shows their location:

Table 1 Sources greater than 0.5 tpy in Washington

Facility Type Site Name County Emissions (tpy) Distance to

ID border

(miles) Distance to
OR border

(miles)

Airport Auburn Muni King 0.61 242 122

Glass Plant Saint

- Gobain Containers, Inc. (Verallia) King 0.54 245 135

Airport Harvey Field Snohomish 0.54 233 160



### Because of their considerable distance to state borders and the physical properties of Pb, the sources listed in Table 1 are unlikely to contribute significantly to nonattainment, or interfere with maintenance, in another state.

Figure 1 Location of lead sources greater than 0.5 tpy in Washington (red circles).



### Closer to the borders, there are several lead sources reporting less than 0.5 tpy according to the

2011 NEI. Sources between 0.1 and 0.5 tpy located in counties bordering other states are shown in Figure 2. The largest source reports 0.16 tpy and corresponds to the Felts Field Airport in

5

### Spokane. The list of all sources smaller than 0.5 tpy located in bordering counties is in the Appendices

.

Since the Guidance suggests that sources smaller than 0.5 tpy are not likely to result in significant impact to neighboring states, no further analysis was performed. In addition , there are no areas in nonattainment or maintenance with respect to the 2008 lead NAAQS in Oregon or Idaho. In fact, Pb levels measured in the Portland

- Vancouver

- Beaverton area are well below the standard (see Appendix A, Figure A

- 2). The monitor located at the Portland

- Vancouver

Beaverton area (Multnomah site) is located near the Oreg on

- Washington border. The only monitor currently measuring Pb in Idaho is located in Ada County which is far enough from the

border and does not represent transport of Pb, at least in the coarse fraction, originat ing in Washington.

After reviewing all the evidence gathered, Ecology is confident affirming that Washington sources are unlikely to contribute significantly to nonattainment, or interfere with maintenance,

with respect to the 2008 l ead NAAQS.

Figure 2 Lead s ourc es greater than 0.1 tpy and smaller than 0.5 tpy (red circles), located in bordering counties.



### 6

# Interstate Transport of Nitrogen Dioxide

Background

Nitrogen dioxide (NO 2 

### ) is one of the components of the nitrogen oxides (NOx) group. EPA’s NAAQS uses NO 2 

### as an indicator for NOx. The main source of NO 2 

### is combustion processes. A small percentage of NO 2 

### is directly emitted but the majority is formed rapidly from nitric oxide (NO) emissions from transportation, power plants, off

- road equipment and biomass burning.

NO 2 

### is regulated due to its harmful effect on health. NO 2 

### exposure has been linked to resp iratory effects including airway inflammation in healthy people and increased respiratory symptoms in people with asthma.

A second reason for the regulation of NO 2 

### is its role in the formation of ground

- level ozone (O 3 

### ) and fine particulate material (PM 2 .5 

### ). NO 2 

### impacts the ozone cycle directly through photolysis, favoring O 3 

### production. Depending on the level of hydroxyl (OH) radicals present, NO 2 

### can react to form nitric acid (HNO 3 

### ) instead. This is the main atmospheric loss process for NOx.

Nitric acid can either react with ammonia (NH 3 

### ) to form ammonium nitrate (NH 4 

### NO 3 

### ) (which is a main component of PM 2.5 

### ) or be lost through deposition processes (wet and dry) resulting in

“acid rain”.

NO 2 

### lifetime in the urban atmosphere is fairly short (~2

- 6 hour s 7 

### ). As a result, transport of NO 2 

### from urban sources is not common, and interstate transport issues are linked to ozone and PM 2.5 

### instead. The main concern regarding NO 2 

### is near

- road exposure in areas with traffic congestion

. Monitoring efforts are usually located close to roads, resulting in air quality data associated with local impacts rather than transport issues.

The first primary standard for NO 2 

### was set by EPA in 1971 as 53 ppb (parts per billion) averaged annually. EPA has reviewed the standard twice since then, however, in both occasions it decided

not to revise it. Instead, in 2010, EPA established an additional primary standard for NO 2 

### at a
level of 100 p art per billion (ppb) , based on the 3

- year average of the 9 8 th 

### percentile of the yearly

distribution of 1

- hour daily maximum concentrations

. On February 17, 2012, EPA published the

final NO 2 

### designations 8 

### identifying all areas in the United States as unclassifiable/attainment for

the 2010 1

- hour NO 2 

### NAAQS.



# Washi ngton’s approach

In September 2009 , EPA issued a Guidance on SIP Elements Required Under Section 110(a)(1) and (2) for the 8

- hour Ozone and PM 2.5 

### NAAQS (Harnett Guidance). In this guidance, EPA directed states to develop an adequate technical analysis to support state’s findings and

7 See Beirle et al

., Mega city Emissions and Lifetimes of Nitrogen Oxides Probed from Space , Science 333, 1737 (2011)

8 See EPA

- HQ

- OAR

- 2011

- 0572



### 7

### conclusions. However, the re was no guidance suggest ing how to approach a technical analysis

for NO 2



### . Therefore, Ecology devised the most reasonable methodology possible taking into consideration other states submittals, emission inventories, ambient data available for th e region and the significant fact that all areas are designated attainment or unclassifiable for the 2010 1

- hour NO 2 

### NAAQS.

Ecology’s approach included the examination of ambient data for states borderin g Washington

within a 50 kilometer radius

, the standard distance for modeling analysis 9 

### consistent with EPA’s Modeling Guideline

. Additionally, Ecology reviewed the most recent NOx emissions inventory for the state of Washington and evaluate d state trends

.

9 Appendix W to 40 CFR Part 51



### 8

# Transport Assessment

Emissions Inventory

The last detailed emissions inventory (EI) for the State of Washington was developed by Ecology in 2011. Table 2 lists anthropogenic source categories used in the 2011 EI:

Table 2 201 1 Washington State NOx Emissions Inventory of anthropogenic sources

Source Category Emissions (tons/year)

On

- road mobile sources 164,130

Non

- road mobile except locomotives , ships and aircraft 31,467

Point sources 26,361

Others Commercial marine vessels 20,486

Locomotives 15,026 Residential fuel use: natural gas, oil, LPG 4,589

Recreational boats 3,530 Aircraft: military, commercial, general aviation 3,309
Woodstoves, fireplaces, inserts 1,803
Agricultural and silvicultural burning 1,621
Residential outdoor burning: yard waste and trash 557

Commercial fuel use: natural gas, LPG 204

Miscellaneous 28



### According to Table 2, O n

- road mobile sources comprise 57 percent of total NOx emissions,

N on

- road mobile sources represent 11 percent, and the third largest group, Point s ources, comprise s 9 percent of all the N Ox emissions in Washington in 2011

. It is worth mentioning that one of the main point sources (TransAlta Centralia Power Plant ) is expected to shut down its two

coal

- fired boiler s: one in 2020 and the second 2025 10



### .

National trends indicate that NOx emissions have decreased substantially since 1980 11



### . Stricter

standards for mobile sources as well as regulations for industrial sources suggest that this trend

will continue. Ecolo gy performed a standard run of the updated Motor Vehicle Emission Simulator (MOVES2014 , database version 20141021 ) for Washington , to look specifically at
future trends in on

- road and non

- road mobile sources 12 

### reported for the state

. Figure 3 shows the

res ult of the modeling run. On

- road mobile sources are divided by type of fuel (ORMgas and ORMdiesel). Figure 3 also shows available NO 2 

### ambient air monitoring data at the Beacon

- Hill monitoring station that represents the Seattle

- Tacoma

- Bellevue area, whic h is the most populated

area of the state :

10 “ BART Determination Document, TransAlta Centralia Power Plant ”

, Washington State Department of Ecology,

revised November 2011

11 http://www.epa.gov/airtrends/nitrogen.html

12 MOVES2014 incorporates EPA’s NONROAD2008 model



### 9Figure 3 Ambient air monitoring levels 13 and e mission estimates for the ma i n categories contributing to NOx in Washington



### The past trend estimated with MOVES 2014 show a steady decrease in NOx emissions from mobile sources, which overall agrees with the observed ambient values measured at Beacon

- Hill. The projected trend suggests that mobile contributions to NOx emissions in the state will

continue to decrease.

Currently, there are no nonattainment areas with respect to the 2010 1

- hour NO 2 

### NAAQS in neighboring states. Ecology concludes that since Washington NOx emissions are projected to continue a decreasing trend, it will be even less likely that Washington s ources will significantly contribute to nonattainment, or interfere with maintenance, in any other state with respect to the

2010 1

- hour NO 2 

### NAAQS.

13 Data obtained from AirData website. Data shown is only for comparison of trends and does not necessarily meet
the completeness criteria. 0 5 10 15 20 25 30 35

0 100 200 300 400 500 600 700 800ambient NOx (ppb)NOx (tons/day)

Year ORMgas

ORMdiesel

non

- road

Beacon

- Hill



### 10

## Air Quality Data and Design V alues for neighboring states

The monitoring site measuring NO 2 

### in n eighboring states and within a 50 kilometer radius is in Oregon. Table 3 lists this site’s characteristics

. Table 4 shows the latest three design values for

the Portland

- Vancouver

- Beaverton area, which is the only station meeting the completeness

criteri a in neighboring states. The design values presented cover a period of 5 years (2009

- 2013):

Table 3 Oregon monitoring site measuring NO 2

State County CBSA Site Address Completeness
Criteria Met

OR Multnomah Portland

- Vancouver

Beaverton, OR

- WA 410510080 5824 SE Lafayette Y

Table 4 NO 2 Design values at the Oregon monitoring site

CBSA Site Average 2009

- 2011 (ppb) 2010

- 2012 (ppb) 2011

- 2013 (ppb)

Portland

Vancouver

Beaverton,

OR

- WA 410510080 1 hour 36 34 34



### The monitoring site located in the OR

- WA border is currently in attainment with respect to the

2010 1

- hour NO 2 

### NAAQS. Therefore, Ecology concludes that Washington sources do not contribute significantly to nonattainment, or interfere with maintenance, in any other state with respect to the 2010 1

- hour NO 2 

### NAAQS.

11

# Interstate Transport of Ozone

Background

Ground

- level ozone is the primar y component of smog. Ozone that occurs naturally in the upper portions of the eart h ’s atmosphere, often referred to as “good ozone”

, forms a layer that protects life on earth from the sun’s harmful rays

. Ozone that forms at ground level , or “bad ozone”, is harmful to breath and damaging to sensitive vegetation and ecosystems

. Ground l evel o zone forms when emissions of nitrogen oxides (NO

x 

### ) and volatile organic compounds (VOCs) “cook”

in the sun making it mainly a summertime pollutant

. The major sources of human

- made NO

x 

### and VOCs are emissions from industrial facilities, electric utilities, motor vehicle exhaust, gasoline vapors, and chemical solvents. Ozone pollution can be transported through air over

hundreds of miles and can affect both urban and rural areas.

Brea thing air containing ozone can reduce lung function and increase respiratory symptoms, thereby aggravating asthma or other respiratory conditions. Ozone exposure also has been associated with increased susceptibility to respiratory infections, medication use by asthmatics, doctor visits, and emergency department visits and hospital admissions for individuals with respiratory disease. Ozone exposure may also contribute to premature death, especially in people with heart and lung disease. In addition, scie ntific evidence showed that repeated exposure to ozone damages sensitive vegetation and trees, including those in forests and parks, leading to reduced growth and productivity, increased susceptibility to disease and pests, and damaged foliage.

On M arch 12, 2008, EPA strengthened ground

- level ozone NAAQS. EPA revised the “primary”, or health

- based, and “secondary”, ecosystem and welfare

- based, 8

- hour standard s to a level of 0.075 parts per million (ppm). In setting the standard, EPA reviewed more than 1 700 new scientific studies indicating strong evidence of adverse health impact of ozone at the level

above the new standard. However, t his standard was not as p rotective as recommended by

EPA’ s panel of scientific advisors (Clean Air Scientific Advisory C ommittee) and was challenged in court

. Subsequently, EPA proposed to reconsider the standard in 2009 . In January 2010, EPA proposed that the new standard is set within the range of 0.060 ppm to 0.070 ppm. However, in September 2011, the Administration i ssued a statement requesting EPA to withdraw

the proposal and continue to implement the standard that was set in 2008 in anticipation of the upcoming scientific and policy review to support the next revision o f the ozone standard

. At this time, EPA is under a court

- ordered deadline t o promulgate a new or revise existing ozone

standard s in December 2015.

Efforts by the EPA and states to addre s s ozone transport have historically been focused on

reductions of NO

x 

### . Between 1990 and 2006, ground

- level ozone declined 9% nationwide. Eighty

- nine of the original one hundred twenty

- six areas designated nonattainment for the 1997

standar d met that standard during the 2004

- 2006 period. EPA continues to implement measures

to reduce ozone interstate transport throug h implementation of the 2005 Clean Air Interstate

Ru le (CAIR), the 2003 NOx Budget Trading Program, and the 2011 Cross

- State Air Pollution Rule ( a litigation

- related stay on this rule was lifted in October 2014)

.

12

# Washington’s approach

On January 22, 201 5, EPA issued a Memorandum on Information of the Interstate Transport “Good Neighbor” Provision for the 2008 Ozone National Ambient Air Quality Standards (NAAQS) under Clean Air Act ( CAA) Section 110(a)(2)(D)(i)(I)

. The attachment to the

memorandum highli ghts the results from the Air Quality Modeling Technical Support Document for the 2008 Ozone NAAQS Transport Assessment 14 

### (Ozone Transport TSD)

. In the Ozone Transport TSD document, EPA details photochemical air quality modeling it performed to project ozone concentrations at air quality monitoring sites to 2018 and to estimate state

- by

- state
contributions to those 2018 concentrations. In its anal ysis, EPA applies t he CSARP approach including the approach for identifying nonattainment and maintenance receptors and for identifying upwind states that contribute to these r eceptors based on the screening threshold (1 percent of the NAAQS) . The memoran dum states that based on the modeling results a state could either demonstrate that its contribution is below the screening threshold, or it could evaluate the scope of its transport obligation and indentify measures to achieve any needed

emissions reducti ons.

Ecology reviewed EPA’s modeling of ozone interstate transport for Washington

. It indicates that most western states contribute less than 1 percent to downwind nonattainment or maintenance

receptors . Washingto n’s contribution is estimated to be sign ificantly less than the screening

threshold. Following the CSARP approach , the memorandum confirms that contributions below the screening threshold do not need further evaluation for actio ns to address transport.

In accordance with EPA’s approach in CSA RP and the 2015 “Good Neighbor” Memorandum

, and based on the O zone Transport TSD findings , Ecology asserts that Washington sources do not contribute significantly to n onattainment areas or interfere with maintenance of the 2008 ozone NAAQS.



# Transport As sessment

Appendix B contains EPA 2015 “Good Neighbor” Memorandum and its attachment discussing Air Quality Modeling Results. The Ozone Transport TSD is available on EPA’s website at http://www.epa.gov/airtransport/O3TransportAQModelingTSD.pdf

.

14 http://www.epa.gov/airtransport/



### 13

# Appendi x

.

A. Additional information on Interstate Transport of

Lead

Figure A 1 Lead sources (<0.5 tpy) in all bordering counties.



### 14Table A 1 List of all lead sources smaller than 0.5 tpy located in bordering counties

County Lead (tons) Site Name Facility Type

Spokane 0.16 Felts Field Airport

Clark 0.14 Pearson Field Airport

Benton 0.12 VISTA FIELD Airport

Cowlitz 0.11 Kelso

- Longview Airport

Spokane 0.1 Deer Park Airport

Klickitat 9.41E

- 02 Columbia Gorge Regional Airport

Benton 8.03E

- 02 Richland Airport

Walla Walla 7.73E

- 02 Walla Walla Regional Airport

Spokane 7.16E

- 02 Spokane Intl Airport

Whitman 7.06E

- 02 Pullman/Moscow Regional Airport

Cowlitz 4.15E

- 02 Weyerhaeuser NR Company Pulp and Paper Plant

Benton 3.66E

- 02 Prosser Airport

Whitman 3.60E

- 02 Whitman Co Memorial Airport

Clark 2.77E

- 02 Grove Field Airport

Whitman 2.65E

- 02 WILLARD FIELD Airport

Cowlitz 2.55E

- 02 Longview Fib er Pulp and Paper Plant

Klickitat 2.30E

- 02 Roosevelt Regional Landfill Landfill

Whitman 2.16E

- 02 Rosalia Muni Airport

Spokane 1.61E

- 02 MEAD FLYING SERVICE Airport

Klickitat 1.44E

- 02 GOLDENDALE Airport

Pacific 1.40E

- 02 PORT OF ILWACO Airport

Walla Walla 1.39E

- 02 MARTIN FIELD Airport

Clark 1.02E

- 02 FLY FOR FUN Airport

Clark 9.71E

- 03 GOHEEN Airport

Clark 9.54E

- 03 WOODLAND STATE Airport

Pacific 7.24E

- 03 WILLAPA HARBOR Airport

Clark 6.50E

- 03 Georgia

- Pacific Consumer Products (Camas) LLC Pulp and Paper Plant

Klickitat 5.50E

- 03 Roosevelt Landfill Biogas Project No. 1 Electricity Generation via
Combustion

Pend
Oreille 4.58E

- 03 Ione Muni Airport

Clark 2.82E

- 03 CEDARS NORTH AIRPARK Airport

Spokane 2.67E

- 03 Mutual Materials Brick, Structural Clay, or Clay
Ceramics Plant

Walla Walla 1.88E

- 03 Boise White Paper LLC Pulp and Paper Plant

Benton 1.85E

- 03 U.S. Dept of Energy

Clark 1.80E

- 03 PARKSIDE AIRPARK Airport

Whitman 1.64E

- 03 SCHOEPFLIN Airport

Spokane 1.45E

- 03 OX MEADOWS Airport

Clark 1.23E

- 03 BRUSH PRAIRIE AERODROME Airport

Clark 1.23E

- 03 GREEN MOUNTAIN Airport



### 15County Lead (tons) Site Name Facility Type

Spokane 1.09E

- 03 SKY MEADOWS AIRPARK Airport

Clark 1.03E

- 03 WALTER SUTTONS PRIVATE STRIP Airport

Pend
Oreille 1.00E

- 03 Ponderay Newsprint Company Pulp and Paper Plant

Spokane 1.00E

- 03 Honeywell Electronic Materials

Cowlitz 9.91E

- 04 MOUNT ST HELENS AERO RANCH Airport

Spokane 9.90E

- 04 HOMEPORT Airport

Clark 9.26E

- 04 LA CENTER VIEW

- AIR Airport

Clark 9.26E

- 04 PLEASANT FARM Airport

Garfield 9.12E

- 04 DYE SEED RANCH INC. Airport

Spokane 8.87E

- 04 FOWLERS NW 40 Airport

Spokane 8.87E

- 04 ELLERPORT Airport

Whitman 8.72E

- 04 GOSSARD FIELD Airport

Skamania 8.63E

- 04 KEY WAY Airport

Benton 8.57E

- 04 WOODFIELD Airport

Spokane 8.36E

- 04 LEES Airport

Pend
Oreille 8.32E

- 04 SULLIVAN LAKE STATE Airport

Columbia 8.32E

- 04 LITTLE GOOSE LOCK AND DAM Airport

Whitman 8.32E

- 04 LOWER GRANITE STATE Airport

Walla Walla 8.32E

- 04 LOWER MONUMENTAL STATE Airport

Clark 8.24E

- 04 BECKER FIELD Airport

Whitman 8.21E

- 04 HILL Airport

Whitman 8.14E

- 04 OAKESDALE Airport

Benton 8.06E

- 04 COOPERS LANDING Airport

Spokane 7.85E

- 04 SPANGLE FIELD Airport

Spokane 7.85E

- 04 BOYLE R & D Airport

Spokane 7.85E

- 04 HARRIS Airport

Spokane 7.85E

- 04 MULLAN HILL Airport

Spokane 7.85E

- 04 ISAACSON Airport

Spokane 7.85E

- 04 FLYING R RANCH Airport

Spokane 7.85E

- 04 PETES Airport

Spokane 7.85E

- 04 TAIS LANDING Airport

Clark 7.72E

- 04 ROBERT L DELANOY Airport

Clark 7.72E

- 04 DAYBREAK Airport

Clark 7.72E

- 04 MC CLELLAN FIELD Airport

Klickitat 7.63E

- 04 SPRING CREEK RANCH Airport

Whitman 7.19E

- 04 LACROSSE MUNI Airport

Klickitat 7.12E

- 04 TROUT LAKE Airport

Klickitat 7.12E

- 04 PORT ELSNER Airport

Skamania 7.09E

- 04 BROWNS CAPE HORN Airport

Columbia 7.08E

- 04 WELLER CANYON Airport



### 16County Lead (tons) Site Name Facility Type

Walla Walla 6.71E

- 04 PAGE Airport

Walla Walla 6.71E

- 04 DARCYS AIR STRIP Airport

Whitman 6.67E

- 04 WALKER Airport

Asotin 6.61E

- 04 HAWKS RUN Airport

Klickitat 6.61E

- 04 AEROSTONE RANCH Airport

Klickitat 6.61E

- 04 BOBS FIELD Airport

Klickitat 6.61E

- 04 PIPER CANYON Airport

Klickitat 6.61E

- 04 MERCER RANCH Airport

Pacific 6.61E

- 04 MARTIN Airport

Skamania 6.58E

- 04 SKY RIVER RANCH Airport

Garfield 6.56E

- 04 SCOTT SEED FARM Airport

Wahkiakum 6.56E

- 04 MICHAIR Airport

Spokane 5.71E

- 04 CHENEY Rail Yard

Spokane 5.43E

- 04 TRENTWOOD Rail Yard

Klickitat 5.00E

- 04 SDS Lumber Company Lumber/Sawmill

Cowlitz 4.19E

- 04 Emerald Kalama Chemical, LLC Chemical Plant

Spokane 2.93E

- 04 SI Rail Yard

Spokane 2.39E

- 04 PARADISE AIR RANCH Airport

Cowlitz 2.22E

- 04 Mint Farm Generating Station Electricity Generation via
Combustion

Clark 2.22E

- 04 VANCOUVER Rail Yard

Klickitat 2.00E

- 04 HILLCREST Airport

Spokane 1.88E

- 04 SPOKANE Rail Yard

Cowlitz 1.60E

- 04 KALAMA Rail Yard

Whitman 1.60E

- 04 Washington State University Institutional (school, hospital, prison, etc.)

Asotin 1.39E

- 04 ROGERSBURG Airport

Spokane 1.28E

- 04 N A DEGERSTROM YARD Airport

Klickitat 1.28E

- 04 MID

- COLUMBIA MEDICAL CENTER Airport

Spokane 1.28E

- 04 HOLY FAMILY HOSPITAL Airport

Skamania 1.28E

- 04 AIR COLUMBIA Airport

Spokane 1.28E

- 04 SHAMROCK PORT Airport

Clark 1.28E

- 04 ORBIT Airport

Walla Walla 1.28E

- 04 ST MARY MEDICAL CENTER Airport

Asotin 1.28E

- 04 O & M FACILITIES Airport

Benton 1.28E

- 04 KENNEWICK GENERAL HOSPITAL Airport

Walla Walla 1.28E

- 04 WALLA WALLA GENERAL HOSPITAL Airport

Benton 1.28E

- 04 WNP

- 2 PLANT SUPPORT FACILITY Airport

Clark 1.28E

- 04 LEGACY SALMON CREEK HOSPITAL Airport

Skamania 1.28E

- 04 RAINCREEK Airport

Spokane 1.28E

- 04 DEACONESS MEDICAL CENTER Airport

Pacific 1.28E

- 04 WILLAPA HARBOR Airport



### 17County Lead (tons) Site Name Facility Type

Spokane 1.28E

- 04 SACRED HEART MEDICAL CENTER
HELISTOP Airport

Pacific 1.28E

- 04 OCEAN BEACH HOSPITAL Airport

Skamania 1.28E

- 04 SAMPSON Airport

Pend
Oreille 1.28E

- 04 METALINE RADIO Airport

Pend
Oreille 1.28E

- 04 BOUNDARY SUBSTATION Airport

Whitman 1.28E

- 04 WHITMAN COMMUNITY HOSPITAL Airport

Klickitat 1.28E

- 04 SKYLINE HOSPITAL EMS Airport

Clark 1.28E

- 04 ST JOSEPH COMMUNITY HOSPITAL Airport

Cowlitz 1.28E

- 04 ST JOHNS MEDICAL CENTER Airport

Asotin 1.28E

- 04 TRI

- STATE HOSPITAL EMS Airport

Benton 1.28E

- 04 KADLEC MEDICAL CENTER Airport

Spokane 1.28E

- 04 PATHFINDER HELICOPTER Airport

Pend
Oreille 1.28E

- 04 NEWPORT COMMUNITY HOSP Airport

Clark 1.28E

- 04 ROSS COMPLEX Airport

Garfield 1.28E

- 04 LOWER GRANITE DAM Airport

Cowlitz 1.28E

- 04 COUGAR Airport

Clark 1.28E

- 04 SOUTHWEST WASHINGTON
MEDICAL CENTER Airport

Benton 1.28E

- 04 HAMMER EVOC SKID PAD Airport

Spokane 1.28E

- 04 EASTERN STATE HOSPITAL EMS Airport

Asotin 1.28E

- 04 KIWI AIR Airport

Asotin 1.28E

- 04 TRI

- STATE MEMORIAL HOSPITAL
EMS Airport

Klickitat 1.27E

- 04 WISHRAM Rail Yard

Spokane 1.14E

- 04 Kaiser Trentwood Fabricated Metal Products Plant

Spokane 8.32E

- 05 YARDLEY Rail Yard

Benton 8.00E

- 05 Agrium US Inc

Spokane 7.77E

- 05 Inland Empire Paper Pulp and Paper Plant

Spokane 5.58E

- 05 MARSHALL Rail Yard

Cowlitz 4.88E

- 05 LONGVIEW JCT. Rail Yard

Walla Walla 3.76E

- 05 WALLUA Rail Yard

Asotin 2.77E

- 05 SNAKE RIVER Airport

Spokane 7.69E

- 06 TIGHTCLIFF Airport

Wahkiakum 7.69E

- 06 SKAMOKAWA EAST VALLEY Airport

Whitman 7.69E

- 06 MC GREGOR Airport

Pacific 7.69E

- 06 WIRKKALA Airport

Pend
Oreille 7.69E

- 06 RIVER BEND Airport

Benton 7.69E

- 06 MC WHORTER RANCH Airport

Klickitat 7.69E

- 06 WARWICK Airport

Columbia 7.69E

- 06 TOUCHET VALLEY Airport



### 18County Lead (tons) Site Name Facility Type

Spokane 7.69E

- 06 ELK HEIGHTS Airport

Benton 7.69E

- 06 COLUMBIA CREST WINERY Airport

Cowlitz 7.69E

- 06 FLYING K RANCH Airport

Cowlitz 7.69E

- 06 WALTERS ARV Airport

Asotin 7.69E

- 06 SKID ROW Airport

Spokane 7.69E

- 06 Fairchild AFB Airport

Clark 1.51E

- 06 Clark Public Utilities / River Road Generating Project Electricity Generation via
Combustion



### 19Figure A 2 Available daily mean values of lead at the Multnomah monitoring site 0 0.01 0.02 0.03 0.04 0.05 0.06

1/1/12 4/30/12 8/28/12 12/26/12 4/25/13 8/23/13 12/21/13 4/20/14Pb (μg/m3) 

### Multnomah



### 20

# B. EPA 2015 “Good Neighbor” Memorandum

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