NIKKI R. HALEY GOVERNOR

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COtUMBJA. SC 29201

January 25, 2011

Gwendolyn Keyes Fleming, Esq.

Regional Administrator

US EPA Region 4

Atlanta Federal Center

61 Forsyth Street, S.W.

Atlanta, GA 30303-8909

Re: South Carolina Recommendationsfor Nitrogen Dioxide (N02) Boundary Designations

Dear Ms. Fleming:

I am writing this letter in response to the United States Environmental Protection Agency's

(EPA) request to submit boundary recommendations for the revised I-hour primary National

Ambient Air Quality Standard (NAAQS) for Nitrogen Dioxide established by the EPA via 75

Federal Register 6474, February 9, 2010.

Section 107(d)(l) provides that, "By such date as the Administrator may

reasonably require, but not later than 1 year after promulgation of a new or

revised NAAQS for any pollutant under section 109,the Governor of each State

shall * * * submit to the Administrator a list of all areas (or portions thereof) in

the State" that should be designated as nonattainment, attainment, or

unclassifiable for the new NAAQS.. ..Accordingly,Governors must submit their

initial N02 designation recommendationsto EPA no later than January [25]12011

(75 FR 6520).

Given the text of the final rule and the deployment of a new N02 near-road monitoring network,

the EPA discusses the issue of boundary recommendations specifically:

A near-roadway monitoring network is not expected to be fully deployed until

January 2013 therefore, EPA must proceed with initial designations using air

quality data from the existing N02 monitoring network. Because none of the

current N02 monitors are sited to measure near-roadway ambient air, we expect

that most areas in the country with current N02 monitors will not violate the new

N02 NAAQS (75 FR 6521).

1Date included in November 12,2010, letter ITomEPA Region 4 Administrator to Governor requesting submission

ofN02 Recommendations.

-- --
In fact, according to the EPA's websiteZ,there are currently no areas in the U.S. that are

designated as nonattainment for the NOzNAAQS. To be sure, after a review of the most recent

quality-assured air quality data from the current monitoring network by the staff of the South

Carolina Department of Health and Environmental Control, I am pleased to report that our state

is in full compliance with the I-hour primary NAAQS for NOz.

With regard to the planned near-road NOzmonitoring network, South Carolina would like to

again3take this opportunity to express its concern. South Carolina, as well as many other states,

has fallen upon hard economic times and funding for the essential services that are provided for

its citizens is dwindling. The proposed NOzmonitoring network will require adding new

monitors or replacing ones already in place that may be serving a specific need or priority for our

state. The siting requirements for these monitors and the cost to service these monitors will

likely lead to further cuts in monitoring of other critical pollutants in order to establish a

monitoring network that the EPA has not fullyjustified.

Based on the aforementioned NOz monitoring information, and the myriad of concerns expressed

by its own Clean Air Scientific Advisory Committee (CASAC)4,it would seem prudent for the

EPA to postpone the implementation of the newNOz monitoring network. However, should

postponement of the network not be an option, at the very least, I am again recommending that

the entire State of South Carolina be designated as "attainment" for the I-hour primary NAAQS

for NOz until such time as certified data demonstrates otherwise.

Should you have any questions regarding our recommendation, please contact Myra Reece,

Chief, Bureau of Air Quality, SC Department of Health and Environmental Control, at (803)

898-4123 or by email atreecemc@dhec.sc.gov.

NH/mw

cc: C. Earl Hunter, Commissioner, SCDHEC

Robert W. King, Jr., P. E. Deputy Commissioner, SCDHEC, EQC

Myra C. Reece, Chief, SCDHEC,BAQ

2 http://www.epa.gov/airQualitv/greenbook/nindex.html, Accessed November 30,2010.

3 September 9, 2009, DHEC letter, Docket ID No. EPA-HQ-OAR-2006-0922-0378.1

4 Statements made during the August 10, 2009, CASAC Oxides of Nitrogen Primary NAAQS Panel

Teleconference to Provide Comments Concerning EPA's Proposed Rule on the N02 NAAQS,

http://yosemite.epa.gov/sab/sabproduct.nsf/MeetingCaVFBC637D2C1B97500852575EF005DBBA9?Ope

nDocument, Accessed November 30,2010.