A	B	C	D	E	F	G
1	Proposed Pb I-SIP Rule Changes	This rule change WILL address	This rule change WILL NOT address	Notes from B.Finneran's discussion w/ EPA (BOLDED TEXT IN ALL CAPS = Lead Rule Writer questions)	Notes from Anthony Barnack	Notes from Phil Allen
2	Section 110(a)(2)(A) Emission limits and other control measures	Permit conditions affected by revissions to OAR 340-202-0130?	OAR340-202-0130 (revised 5/21/10 to reflect updated NAAQS value of 0.15 μg )	Guidance on Section 110 Infrastructure SIPs for the 2008 Pb NAAQS @ http://www.epa.gov/air/lead/pdfs/20111014infrastructure.pdf
3	Section 110(a)(2)(B) Ambient air quality monitoring/data system		X			• Date of last assessment The last five year assessment was done in July 2010. The last annual assessment was done in July 2012. • Conclusions of assessment The report is an adjustment of the network to balance the monitoring requirements and needs with the budget restrictions. Last year’s biggest conclusion was where we were going to place the NO2 roadway site and what monitors we were going to discontinue to pay for the new monitoring. The conclusion of the five year assessment was that we needed to monitor in areas with population density growth from 2000 to 2010. These include Hillsboro, Gresham, and Oregon City. We also where satisfied with most of our monitoring. • Documentation submitted to EPA of assessment and results DEQ submits all the network plans to EPA Region 10 for approval. http://www.ecfr.gov/cgi-bin/text-idx?c=ecfr&SID=62a804d300890c5dc3e8d18d5143cb75&rgn=div5&view=text&node=40:6.0.1.1.6&idno=40#40:6.0.1.1.6.2.1.1
4	Section 110(a)(2)(C) Program for enforcement of control measures		X
5	Section 110(a)(2)(D)(i) - I Prong 1: Interstate transport - significant contribution						We use AERMOD for all near source (<= 50 km) modeling, and CALPUFF for all pollutant modeling > 50 km.
6	Section 110(a)(2)(D)(i) - I Prong 2: Interstate transport - interfere with maintenance	?			• Pretty easy, since there are no nonattainment or maintenance areas for SO2, NO2, or Lead in any neighboring state. WHEN AND HOW WAS THIS CONFIRMED?
7	Section 110(a)(2)(D)(i) - II Prong 3: Interstate transport - prevention of significant deterioration		X		No PSD rule changes needed. DEQ rules already been changed to reflect new NAAQS.
8	Section 110(a)(2)(D)(i) - II Prong 4: Interstate transport - protect visibility		X
9	Section 110(a)(2)(D)(ii) - Interstate and international pollution abatement		X
10	Section 110(a)(2)(E) Adequate authority and resources	Using crosswalk template from PM2.5
11	Section 110(a)(2)(F) Stationary source monitoring system	?				We have one PM10 lead sampler at SE Lafayette which is our NCore site. Monitors are federal reference method. TSP lead is measured by drawing air through a glass fiber filter using a high volume particulate sampler. PM10 lead for air toxics is measured with quartz filters on high volume particulate samplers with a pm10 inlet. PM10 lead for criteria pollutants is measured using a low volume PM10 sampler with a Teflon filter. In all cases, lead is analyzed on the filter using Inductively Coupled Plasma Mass Spectrometry or ICP-MS.
12	Section 110(a)(2)(G) Emergency power		X		No changes needed to emergency episode rules.
13	Section 110(a)(2)(H) Future SIP revisions	?	X
14	Section 110(a)(2)(J) Consultation with government officials; Public notification; PSD and visibility protection		X
15	Section 110(a)(2)(K) Air quality modeling/data		Oregon designation = unclassified/attainment.			We are in no danger of violating the lead NAAQS.
16	Section 110(a)(2)(L) Permitting fees		X
17	Section 110(a)(2)(M) Consultation/participation by affected local entities		X

	A	B	C	D	E	F
1	Proposed NO2 I-SIP Rule Changes	This rule change WILL address	This rule change WILL NOT address	Notes from B.Finneran's discussion w/ EPA (BOLDED TEXT IN ALL CAPS = Lead Rule Writer questions)	Notes from Anthony Barnack	Notes from Phil Allen
2	Section 110(a)(2)(A) Emission limits and other control measures	REVISE OAR 340-202-0100 to reflect: Nitrogen Dioxide [75 FR 6474, Feb 9, 2010] [61 FR 52852, Oct 8, 1996] primary 1-hour 100 ppb 98th percentile, averaged over 3 years primary	OAR 340-202-0100 annual standard OR Permit conditions affected by revissions to OAR 340-202-0100
3	Section 110(a)(2)(B) Ambient air quality monitoring/data system	?			• Date of last assessment The last five year assessment was done in July 2010. The last annual assessment was done in July 2012. • Conclusions of assessment The report is an adjustment of the network to balance the monitoring requirements and needs with the budget restrictions. Last year’s biggest conclusion was where we were going to place the NO2 roadway site and what monitors we were going to discontinue to pay for the new monitoring. The conclusion of the five year assessment was that we needed to monitor in areas with population density growth from 2000 to 2010. These include Hillsboro, Gresham, and Oregon City. We also where satisfied with most of our monitoring. • Documentation submitted to EPA of assessment and results DEQ submits all the network plans to EPA Region 10 for approval. http://www.ecfr.gov/cgi-bin/text-idx?c=ecfr&SID=62a804d300890c5dc3e8d18d5143cb75&rgn=div5&view=text&node=40:6.0.1.1.6&idno=40#40:6.0.1.1.6.2.1.1
4	Section 110(a)(2)(C) Program for enforcement of control measures		X
5	Section 110(a)(2)(D)(i) - I Prong 1: Interstate transport - significant contribution	?		NO2 – no significant source in Oregon or surrounding states, no NAAs DEQ can follow same formal in report for PM2.5 and Ozone. AND IN SPECIFICS? WHERE DO WE NEED TO DEVIATE FROM THE FORMAT USED FOR PM2.5 AND O3?		We use AERMOD for all near source (<= 50 km) modeling, and CALPUFF for all pollutant modeling > 50 km.
6	Section 110(a)(2)(D)(i) - I Prong 2: Interstate transport - interfere with maintenance	?		• Pretty easy, since there are no nonattainment or maintenance areas for SO2, NO2, or Lead in any neighboring state. WHEN AND HOW WAS THIS CONFIRMED?
7	Section 110(a)(2)(D)(i) - II Prong 3: Interstate transport - prevention of significant deterioration	?		Only EPA guidance for NO2 is for the PSD part.  Guidance “recommends” an interim SIL of 4 ppb. WHAT IS THE WEIGHT OF A RECOMMENDATION? DO WE NEED TO DO ANY ANALYSIS TO GO WITH A RECOMMENDATION OR OTHER CHOICE? No changes needed to emergency episode rules.  No other PSD rule changes needed. WHAT CHANCES ARE NEEDED?  ARE ALL NEEDED CHANGES PSD RELATED? • EPA has issued NO2 modeling guidance to supplement Appendix W. As long as DEQ references using Appendix W for PSD, nothing else needed.		For dispersion modeling the model primarily used is AERMOD, and that would include the modeling of NO2.
8	Section 110(a)(2)(D)(i) - II Prong 4: Interstate transport - protect visibility	?		New standard and MAYBE new SIL
9	Section 110(a)(2)(D)(ii) - Interstate and international pollution abatement	?
10	Section 110(a)(2)(E) Adequate authority and resources	Using crosswalk template from PM2.5
11	Section 110(a)(2)(F) Stationary source monitoring system	?			We have one monitor for NO2 in SE Portland at our National Core site. Next year we will start NO2 monitoring next to I-5 between the I-205 and I-217 interchanges. Monitors are federal reference method. The NO2 is monitored using chemiluminescent detection. I am not sure what model we are currently using but I believe it is a Thermo Scientific Model 42i-LS.
12	Section 110(a)(2)(G) Emergency power
13	Section 110(a)(2)(H) Future SIP revisions	?
14	Section 110(a)(2)(J) Consultation with government officials; Public notification; PSD and visibility protection	?
15	Section 110(a)(2)(K) Air quality modeling/data	?			We are in attainment for NO2 as of now but we are required to install a near road site in 2014 which will have higher NO2.   So I don’t know if we will remain in attainment.
16	Section 110(a)(2)(L) Permitting fees	?
17	Section 110(a)(2)(M) Consultation/participation by affected local entities	?

	A	B	C	D	E	F	G	H	I	J	K	L	M	N	O	P	Q	R
1	Proposed SO2 I-SIP Rule Changes	This rule change WILL address	This rule change WILL NOT address	Notes from B.Finneran's discussion w/ EPA (BOLDED TEXT IN ALL CAPS = Lead Rule Writer questions)	Notes from Anthony Barnack	Notes from Phil	Redline Stikeouts
2	Section 110(a)(2)(A) Emission limits and other control measures	REVISE OAR 340-202-0070 to reflect: Sulfur Dioxide [75 FR 35520, Jun 22, 2010] [38 FR 25678, Sept 14, 1973] primary 1-hour 75 ppb 99th percentile of 1-hour daily maximum concentrations, averaged over 3 years secondary 3-hour 0.5 ppm Not to be exceeded more than once per year	Permit conditions affected by revissions to OAR 340-202-0070
3	Section 110(a)(2)(B) Ambient air quality monitoring/data system	?		Still under dispute is whether compliance with new NAAQS will be modeling or monitoring. Likely a hybrid. New multi-guidance being developed will likely address this. If not, may have to pull out SO2 designation part of this for later. WHEN/HOW WILL WE KNOW?	• Date of last assessment The last five year assessment was done in July 2010. The last annual assessment was done in July 2012. • Conclusions of assessment The report is an adjustment of the network to balance the monitoring requirements and needs with the budget restrictions. Last year’s biggest conclusion was where we were going to place the NO2 roadway site and what monitors we were going to discontinue to pay for the new monitoring. The conclusion of the five year assessment was that we needed to monitor in areas with population density growth from 2000 to 2010. These include Hillsboro, Gresham, and Oregon City. We also where satisfied with most of our monitoring. • Documentation submitted to EPA of assessment and results DEQ submits all the network plans to EPA Region 10 for approval. http://www.ecfr.gov/cgi-bin/text-idx?c=ecfr&SID=62a804d300890c5dc3e8d18d5143cb75&rgn=div5&view=text&node=40:6.0.1.1.6&idno=40#40:6.0.1.1.6.2.1.1
4	Section 110(a)(2)(C) Program for enforcement of control measures	?
5	Section 110(a)(2)(D)(i) - I Prong 1: Interstate transport - significant contribution	X		SO2 – Include discussion on potential Boardman impacts, probably don’t need to model. WHAT DOES "PRPBABLY" HINGE ON? DEQ can follow same formal in report for PM2.5 and Ozone. AND IN SPECIFICS? WHERE DO WE NEED TO DEVIATE FROM THE FORMAT USED FOR PM2.5 AND O3? • SO2 a little more work , since SO2 chemically converts to particulate, and thus travels farther. WHAT IS NEEDED? But no modeling work should be necessary. CONFIDENCE INTERVAL? HOW WAS THIS DETERMINED? HAS THIS BEEN CONFIRMED BY EPA? Focus of report should be the SO2 emissions from PGE Boardman, since they are so significant. HAVE OTHER SOUCES BEEN IDENTIFIED? ANALYZED? HOW WAS THIS CONCLUSION REACHED? Otherwise, low hurtle. WHAT DOES THIS MEAN? b/c SO2 can convert to particulate downwind and transport. BFs convos with Kristin indicate no modeling necessary. QUESTION: NEED TO INCLUDE REASONING FOR NOT MODELING? IF SO, WHAT WAS REASON DISCUSSED? • Should discuss further with Steve Body at EPA R10. Let him review an outline of report, get his feedback.		We use AERMOD for all near source (<= 50 km) modeling, and CALPUFF for all pollutant modeling > 50 km.
6	Section 110(a)(2)(D)(i) - I Prong 2: Interstate transport - interfere with maintenance	X		• Pretty easy, since there are no nonattainment or maintenance areas for SO2, NO2, or Lead in any neighboring state. WHEN AND HOW WAS THIS CONFIRMED?
7	Section 110(a)(2)(D)(i) - II Prong 3: Interstate transport - prevention of significant deterioration	X		Draft PSD guidance “recommends” an interim SIL of 3 ppb. No changes needed to emergency episode rules. BECAUSE? No other PSD rule changes needed. WHAT CHANGES NEEDED? CHANGE SIL TO 3 PPB? ANY JUSTIFICATION NEEDED IF FOLLOW GUIDANCE? EPA has issued SO2 modeling guidance to supplement Appendix W. As long as DEQ references we are using Appendix W for PSD, nothing else needed.
8	Section 110(a)(2)(D)(i) - II Prong 4: Interstate transport - protect visibility	X
9	Section 110(a)(2)(D)(ii) - Interstate and international pollution abatement
10	Section 110(a)(2)(E) Adequate authority and resources	Using crosswalk template from PM2.5
11	Section 110(a)(2)(F) Stationary source monitoring system	X			We have one monitor for SO2 in SE Portland at our National Core site. Monitors are federal reference method. The SO2 is measured using Ultraviolet Fluorescence Spectrometry with the Thermo Scientific Trace Level SO2 Analyzer, Model 43i-TLE.
12	Section 110(a)(2)(G) Emergency power	?
13	Section 110(a)(2)(H) Future SIP revisions	?
14	Section 110(a)(2)(J) Consultation with government officials; Public notification; PSD and visibility protection	?
15	Section 110(a)(2)(K) Air quality modeling/data	X			SO2 is unclassified for all areas.  The SO2 attainment method is still under review by EPA.  Currently attainment will be determined by modeling which many people think is “nuts”.  EPA is looking at some combination of monitoring and modeling to determine attainment.  I don’t think we will violate the standard however.
16	Section 110(a)(2)(L) Permitting fees	?
17	Section 110(a)(2)(M) Consultation/participation by affected local entities	?

	A
1	For each of the states for which the EPA proposes to deny or to partially deny the Petition, the EPA proposes to find that particular provisions in the existing SIP identified by the Petitioner are consistent with the requirements of the CAA and thus not substantially inadequate to meet the requirements pursuant to CAA section 110(k)(5). Thus, the EPA proposes to take no action with respect to those states for those particular SIP provisions. (RE: SSM - Oregon is denied from Sierra Club petition - see email from JI 2/26/13 @ 11:53 am & DRAFT guidance pg. 18)
3	NAAQS standards being used to update OARs referenced from "Table of current NAAQS": http://www.epa.gov/air/criteria.html

	A	B
1	Bundled approach to simultaneisouly submitt I-SIP rulechanges for Pb, SO2 & NO2
2	Updating NAAQS in OARs
3	Updat SHLs? (numerical values, everaging times)
4	110(a)(2)(A) "enforecable emission limitations" = ? (MAAQS only, permit conditions related to NAAQS values?)
5	NOT fastracking this rulemaking, per emails with Nicole
6	Considerations, pros/cons of IBR and historical decisions not to
11	QUESTIONS
12	Because NO2 and SO2 are precusors to PM2.5, do we need to reference and PM rules in the crosswalks?
13	Any need to search for "sulfur" or nitrogen" as stand-alone terms?
14	Jill's rule is repealing several rules for which I have included in the table of rules that contain key words/pollutants - should I be making chages to ruels that will be repealed in Jill's RM, and if so - will the repeals impact the bundled SIP Submitall for Pb, SO2 and NO2?
15		Any rules being repealed in Jill's referenced in the crosswalk?
16	Aside from rules that refernce criteria pollutants, are there any other factors that help determin whehter a rule should have a SIP note at the end of it? (see those rules with a rad line at bottom indicating there is no SIP note in the current version of the rule)
17	It has been explained to me that we do not include SIP notes in our pemritting rules because we do not want to have to revised the SIP when making changes to permit rules - is this acceptable?

	A
1	1)      What monitors are we going to discontinue, if any?
2	We may discontinue the assessment air toxics site currently in Hillsboro if the Legislature take the proposed 15% cut this April.
3	In July, we will discontinue PM10 in White City
4	In January, 2014 we will discontinue PM10 in NW Portland.
5	and
7	2)      What aspects of our monitoring were we not satisfied with, and why?
8	Funding cuts.  We have to run the newly required monitors (NO2 roadway, Pb, and SO2) with no additional funds.  We have to cut existing monitoring to fund these.    We also have aging equipment and need to replace our inventory on a regular basis.
9	Finally, our AQI web site is 10 years old and very antiquated.  We need to update it, and hope to this spring.
13	·        Date of last assessment
14	The last five year assessment was done in July 2010.  The last annual assessment was done in July 2012.
16	·        Conclusions of assessment
17	There is no dramatic conclusion each year.  The report is an adjustment of the network to balance the monitoring requirements and needs with the budget restrictions.   Last year’s biggest conclusion was where we were going to place the NO2 roadway site and what monitors we were going to discontinue to pay for the new monitoring.
18	The conclusion of the five year assessment was that we needed to monitor in areas with population density growth from 2000 to 2010.  These include Hillsboro, Gresham, and Oregon City.  We also where satisfied with most of our monitoring.
20	·        Documentation submitted to EPA of assessment and results
22	We submit all the network plans to EPA Region 10 for approval.
24	http://www.ecfr.gov/cgi-bin/text-idx?c=ecfr&SID=62a804d300890c5dc3e8d18d5143cb75&rgn=div5&view=text&node=40:6.0.1.1.6&idno=40#40:6.0.1.1.6.2.1.1
26	(d) The State, or where applicable local, agency shall perform and submit to the EPA Regional Administrator an assessment of the air quality surveillance system every 5 years to determine, at a minimum, if the network meets the monitoring objectives defined in appendix D to this part, whether new sites are needed, whether existing sites are no longer needed and can be terminated, and whether new technologies are appropriate for incorporation into the ambient air monitoring network. The network assessment must consider the ability of existing and proposed sites to support air quality characterization for areas with relatively high populations of susceptible individuals (e.g., children with asthma), and, for any sites that are being proposed for discontinuance, the effect on data users other than the agency itself, such as nearby States and Tribes or health effects studies. For PM2.5 , the assessment also must identify needed changes to population-oriented sites. The State, or where applicable local, agency must submit a copy of this 5-year assessment, along with a revised annual network plan, to the Regional Administrator. The first assessment is due July 1, 2010.
28	(e) All proposed additions and discontinuations of SLAMS monitors in annual monitoring network plans and periodic network assessments are subject to approval according to § 58.14.