North
Carolina
Department
of
Environment
and
Natural
Resources
Division
of
Air
Quality
Michael
F.
Easley,
Governor
William
G.
Ross,
Jr.,
Secretary
B.
Keith
Overcash,
P.
E.,
Director
1641
Mail
Service
Center,
Raleigh,
North
Carolina
27699­
1641
2728
Capital
Blvd.,
Raleigh,
North
Carolina
27604
Phone:
919­
715­
7670
/
FAX
919­
715­
7476
/
Internet:
www.
ncair.
org
An
Equal
Opportunity/
Affirmative
Action
Employer
 
50%
Recycled/
10%
Post
Consumer
Paper
February
26,
2004
Mr.
James
I.
Palmer,
Jr.,
Regional
Administrator
USEPA,
Region
4
Sam
Nunn
Atlanta
Federal
Center
61
Forsyth
Street,
SW
Atlanta,
Georgia
30303­
8960
Subject:
Technical
Documentation
for
Recommendations
on
PM2.5
Non­
attainment
Designations
Dear
Mr.
Palmer:

On
February
17,
2004,
Department
of
Environment
and
Natural
Resources
Secretary
Bill
Ross
submitted
North
Carolina's
recommendation
for
PM2.5
non­
attainment
boundary
designations.
Pursuant
to
that
letter,
I
am
submitting
to
you
and
your
colleagues
at
EPA
the
State
of
North
Carolina's
technical
analysis
supporting
the
recommendations
for
PM2.5.
designations.

Each
area
is
described
separately
in
the
attached
document
and
satisfies
the
criteria
as
set
forth
in
EPA's
April
1,
2003
memorandum
entitled,
"
Designations
for
the
Fine
Particle
National
Ambient
Air
Quality
Standards".
North
Carolina
has
two
monitors
that
violate
the
fine
particle
standard,
one
in
Hickory
(
Catawba
County)
with
a
15.5
microgram
per
cubic
meter
3­
year
annual
average
for
2001­
2003,
and
one
in
Lexington
(
Davidson
County)
with
a
15.8
microgram
per
cubic
meter
3­
year
annual
average
for
2001­
2003.
All
other
monitors
in
the
state
have
measured
attainment
of
the
standard.

There
is
a
significant
portion
of
fine
particle
pollution
due
to
regional
emissions
sources.
The
upcoming
state
and
federal
controls
on
the
major
sources
of
fine
particle
pollution
will
result
in
significant
emission
reductions
of
this
regional
component
in
the
coming
years.
The
Clean
Smokestacks
Act
will
result
in
considerable
reductions
of
both
SO2
and
NOx
from
North
Carolina
utilities
between
now
and
2009,
and
further
reductions
of
SO2
between
2009
and
2013.
If
finalized,
the
Interstate
Air
Quality
rule
will
result
in
similar
reductions
of
SO2
and
NOx
emissions
from
utilities
in
the
surrounding
states.
The
heavy­
duty
engine
standards
and
the
low
sulfur
diesel
standards
will
begin
to
reduce
pollution
from
the
motor
vehicle
sector
beginning
in
2006.
J.
I.
Palmer,
Jr.
February
23,
2004
Page
2
of
2
North
Carolina
believes
there
also
may
be
a
more
local
component
to
the
particle
pollution
observed
at
these
two
sites.
We
will
be
further
evaluating
these
potential
local
source
emissions
and
will
be
addressing
these
emissions
in
the
fine
particle
State
Implementation
Plan.
In
addition,
North
Carolina
will
be
forecasting
for
high
particle
days
for
these
two
areas
beginning
on
May
1,
2004.
The
general
public
will
then
have
information
on
how
to
better
protect
their
health
during
high
particle
events.
Due
to
the
reasons
stated
above,
and
due
to
the
marginal
nature
of
these
violations,
North
Carolina
believes
smaller
than
MSA
boundaries
are
appropriate
for
our
two
nonattainment
areas.

We
remain
committed
to
protecting
the
air
quality
in
our
state.
We
believe
that
the
recommended
fine
particle
non­
attainment
boundaries
are
appropriate
to
allow
us
to
fulfill
that
goal.

Sincerely,

B.
Keith
Overcash,
P.
E.

BKO/
sh/
lg
attachment
cc:
Secretary
Bill
Ross
Beverly
Banister
Brock
Nicholson
Sheila
Holman
