1. FIP as an Alternative to a SIP: Shoshone-Bannock Tribes Farshid Farsi Shoshone-Bannock Tribes

2. 2 Introduction to FMC: Background uShoshone-Bannock tribes is located in Southeast, Idaho uFMC, Elemental Phosphorous Producing Plant built on tribal fee land in 1949 uFMC ceased operations December 17, 2001

3. 3 FMC Plant

4. 4 Chronology of Events uLast Operating Permit issued by DEQ to FMC in 1980 uIn 1995, Agency for Toxic Substance and Disease Registry (ATSDR) finalized report on impact of air pollution on members of Shoshone-Bannock Tribes uIn 1995, the tribes signed an MOU with FMC regarding air quality

5. 5 Chronology (cont.) uOn October 1996, Tribal Ambient Air Monitoring Network for PM10 constructed uDuring last calendar quarter of 1996, tribal monitors recorded 26 violations of PM10 uAttainment date for Power-Bannock Counties Non-Attainment Area (PBCNAA) Moderate PM10 NAA, December 1996

6. 6 FMC Plant Winter

7. 7 Chronology (cont.) uIn 1998 the PBCNAA was split to 2 NAAs, Fort Hall Moderate PM 10 NAA, Portneuf Valley Moderate PM 10 NAA uIn 1998, EPA and FMC Corporation signed Consent decree

8. 8 FMC Plant Fall

9. 9 Source Apportionment Study uEarly in 1998, Man-Tech began Source Apportionment study using Tribal resources uFederal Implementation Plan (FIP) drafted for FMC in 1999 uFIP finalized August 2000

10. 10 Source Apportionment Study (cont.) uFMC curtailed production by operating only 2 furnaces out of total 4 uIn April 2001, FMC further curtailed production by operating 1 furnace

11. 11 Closure Announcement On October 10, 2001 FMC announced permanent closure of operation in Fort Hall, Idaho uDecember 17, 2001 last furnace was de-energized. uDecember 20, 2001 Turn-down plan began

12. 12 Conclusion uBased on recommendations from Source Apportionment Study, follow-up research began in November, 2001, uUsed filters from newly constructed monitoring station approximately 8 miles Northeast of FMC in more populated area of reservation

13. 13 Final Outcome upermanent closure announcement 10/18/01 uLast electric arc furnace de-energize, 12/17/01 u80 Tribal members became unemployed