From: BAILEY Mark
Sent: Thu Jun 28 16:56:29 2012
To: BIBERIC Aida
Cc: CALKINS Larry
Subject: RE: Klamath Falls PM Plan - Review of Proposed Rulemaking (Round 2 due 6-28-12)
Importance: Normal
Hello Aida. You and the team are doing a fantastic job. I have some comments regarding the attainment plan. They are bulleted below:
· Rulemaking Announcement: Within the announcement we are not consistent on how we express the “2.5” in PM2.5. Sometimes it is in normal font, other times it is in subscript. (PM2.5 vs PM2.5) We should make it consistent.
· Rulemaking Announcement: Under contingency strategies for industrial facilities, we define “grain loading” as the particulate “density”. Grain loading is actually a measurement of particulate “concentration”.
· SOS Notice: Within this notice it says we are going to “require” public agencies to not impact KFalls through prescribed burning. “Require” is a strong word for the agreements we are seeking. Can we soften this somehow, like “forming agreements with public agencies”?
· Land Use Statement: Within the statement we are not consistent on how we express the “2.5” in PM2.5. Sometimes it is in normal font, other times it is in subscript. (PM2.5 vs PM2.5) We should make it consistent.
· Federal Requirement Questions: Like my SOS comment, within paragraph 2 of question 1 it says we are going to “require” public agencies to not impact KFalls through prescribed burning. “Require” is a strong word for the agreements we are seeking. Can we soften this somehow, like “forming agreements with public agencies”?
· OAR 340-204-0010: We have a definition for “Particulate Matter” and “PM10” in this rule section. Don’t we also need a definition for “PM2.5”?
· OAR 225-0090: (2)(a)(D) speaks of sources within nonattainment and maintenance areas, and of sources located outside these areas but significantly impacting them. However, (2)(a) only applies to sources located within a designated nonattainment area. So (2)(a) should be modified as follows: (a) For a source locating within a designated nonattainment area, except as provided in paragraph D below, the owner or operator must comply with paragraphs (A) through (E) of this subsection:
· OAR 225-0090: After paragraph “F” of (2)(a), the next 2 paragraphs should be (b) and (c), thus representing (2)(b) & (2)(c).
· OAR 340-240-510: The opacity limit should have a time duration applied to the standard, much like division 208. It should say something like “..for a period or periods aggregating more than three minutes in any one hour.”
· OAR 340-240-510(1): This opacity standard could be interpreted as being applicable to open burning activities and to woodstoves. Is there a way to make it more specific regarding the sources it applies to? Does it apply to residential wood stoves, or is it limited to commercial activities?
· 340-240-0520(1): Please remove “charcoal manufacturing plants” from this list. There aren’t any in Klamath Falls area.
Thanks
From: BIBERIC Aida
Sent: Friday, June 22, 2012 1:41 PM
To: HAYES-GORMAN Linda; CALDERA Stephanie; ROOT Jenny; KOSS Leah; DECONCINI Nina; MANNION Brian
Cc: SAKATA Rachel; CALKINS Larry; COLLIER David; BAILEY Mark; ARMITAGE Sarah; VICK Nicole R.; BIBERIC Aida
Subject: Klamath Falls PM Plan - Review of Proposed Rulemaking (Round 2 due 6-28-12)
Dear Reviewers,
Thank you for your input during the first round of reviews on the Klamath Falls rulemaking package! This is the second review in this two-round review process and another chance for you to give us any further feedback. Please provide your comments by noon on Thursday, June 28th. Hopefully you have time for this.
We have moved to SharePoint! This link will take you to SharePoint folder where you will find the following documents (expand the first Topic if you don’t see them):
- Rulemaking Announcement,
- SOS Notice of Proposed Rulemaking,
- Land Use Statement,
- Fiscal Statement,
- Federal Requirements Questions, and
- Rules (OAR Div 204, 225, 240, 262, and 264).
In this round we also included a link to the Klamath Falls Attainment Plan (expand Topic: General). The main audience for this document is EPA and at their request this document is fairly technical and succinct. Klamath Falls team worked closely with EPA Region 10 when writing this document; each chapter has been revised several times based on EPA comments. If you are interested, please take a look and let us know if you have any suggestions on how to improve the Plan even further.
Note about SharePoint: if you notice that a document is checked out, please try again in an hour. If the document is still checked out, please send an email to the person who has it checked out and ask when they think they will finish. Make sure that you first check the document out before you start editing, if you don’t you might get an error message. Only one person can edit a document at a time, so please make sure that you check the document back in once you are done with it. Thank you!
Please let me know if you have any questions or concerns.
Thank you,
Aida & Klamath Falls Team
Aida Biberic
Air Quality Planning
Oregon DEQ
(503) 229 - 5280