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STATE OF IDAHO DEPARTMENT OF ENVIRONMENTAL QUALITY OFFICE OF THE EXECUTIVE



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... •.. . 1410 North Hilton. Boise
. Idaho 83706· (208) 373-0502 C

.L. "Butch" Otter. Governor Toni Hardesty. Director September 30, 2009

Michelle Pirzadeh, Acting Regional Administrator USEPA, Region 10 1200 Sixth Avenue, Suite 900 Mail Code: RA-140 Seattle, WA 98101 Dear Ms. Pirzadeh: OnbehalfofGovernor C. 

### L. "Butch" Otter ofIdaho and as the director ofthe Idaho Department ofEnvironmental Quality (DEQ), I am submitting to you Idaho's recommendations for area designations for the 2008 revised lead (Pb) National Ambient Air Quality Standard (NAAQS). Section 107(d)(l) ofthe Clean Air Act defines an area as nonattainment ifit is violating a N.MQS or contributing to a violation in a nearby area. Core Based Statistical Area (CBSA) or Combined Statistical Areas (which includes two ormore CBSAs) associated with violating monitor(s) serve as the starting point or "presumptive" boundary for the geographic extent ofa nonattainment area. For rural areas the presumption is that the designation will be made for the entire county in which the monitor is located. In a recent memo from William Harnett to EPA Regional Administrators, Mr. Harnett states that "EPArecommends states use the most recent three consecutive years of quality assured, certified air quality data. In most cases, EPA expects these data to be from 2006-2008 that are stored in the EPA Air Quality System (AQS)." DEQ has not monitored lead in total suspendedparticulate matter (TSP) since 2002, at the Kellogg Medical Center in Kellogg, Idaho (AQS Site ID 160790006). Thelast three consecutive years ofcomplete data collected at this site were 1999-2001
. For these data; the highest rolling quarterly average was 0.076 llg/m3, approximately 50 percent ofthe 2008 primary and secondary NAAQS, 0.15 llg/m3. This site was terminated, with EPA's approval, because ofa long-term downward trend in lead concentrations well belowthe former lead N.MQS of 1.5 llg/m3. B2.sed onthe above, and on behalfofGovernor Otter, I am recommending that the entire state ofIdaho be designated as unclassifiable for the 2008 lead NAAQS.)

DEQ does not have facilities exceeding the one-ton-per-year threshold as defined inthe 2008 lead NAAQS and will not implement source-oriented lead monitoring required January 1,2010. According to the 2008 Pb NAAQS, DEQ will be required to implement the population-oriented lead monitoring requirementbeginning January 1, 2011, inthe Treasure Valley. Depending onthe outcome ofEPA's reconsideration ofthe 2008 NAAQS, ifthe source emissions threshold triggering source oriented monitoring is loweredto**~** 0.5 tonsper year, DEQ will still notbe required to implement source-oriented lead monitoring. If EP.A increases the urban areapopulation threshold from 500,000 to 1,000,000, DEQ will not meetthis requirement for any urban areas in Idaho, and no population-based lead monitoring will be required. IfEPA has any further questions orconcerns, please contact Martin Bauer, Air Quality Division Administrator, at (208) 373-0552 or martin.bauer@deq.idaho.gov
. Sincerely,

# ~,,'(----/ Toni Hardesty Director
cc: Governor Butch Otter Katie Brodie, Office ofthe Governor