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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: 

On behalfof Governor C. L. "Butch" Otter of Idaho 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 or more CBSAs) associated 

with violating monitor(s) serve as the starting point or "presumptive" boundary for the 

geographic extent of a 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 "EPA recommends 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 suspended particulate matter (TSP) since 2002, at the Kellogg 

Medical Center in Kellogg, Idaho (AQS Site ID 160790006). The last three consecutive 

years of complete 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 of a long-term downward trend in lead concentrations well below the former lead 

N.MQS of 1.5 llg/m3. 

B2.sed on the above, and on behalf of Governor Otter, I am recommending that the entire 

state ofIdaho be designated as unclassifiable for the 2008 lead NAAQS. 
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DEQ does not have facilities exceeding the one-ton-per-year threshold as defined in the 

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 requirement beginning January 1, 2011, in the 

Treasure Valley. 

Depending on the outcome ofEPA's reconsideration of the 2008 NAAQS, ifthe source 

emissions threshold triggering source oriented monitoring is lowered to ~ 0.5 tons per 

year, DEQ will still not be required to implement source-oriented lead monitoring. If 

EP.A increases the urban area population threshold from 500,000 to 1,000,000, DEQ will 

not meet this requirement for any urban areas in Idaho, and no population-based lead 

monitoring will be required. 

If EPA has any further questions or concerns, 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