UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION Ill 

1650 Arch Street 

Philadelphia, Pennsylvania 19103-2029 

The Honorable Robert M. Summers, Secretary 

Maryland Department of the Environment 

1800 Washington Boulevard 

Baltimore, Maryland 21230 

Dear Secretary Summers: 

fEB 1 0 2014 

On December 23, 2013, the U.S. Environmental Protection Agency (EPA) received a 

revision to the Maryland State Implementation Plan (SIP) from the Maryland Department of the 

Environment (MDE). This SIP revision consists of a redesignation request and maintenance plan 

for the Maryland portion of the Hagerstown-Martinsburg, MD, WV 1997 annual fine particulate 

matter (PM2. 5) Nonattainment Area. EPA has determined that the submittal is administratively 

and technically complete, and is reviewing it to prepare a Notice of Proposed Rulemaking (NPR). 

If members of your staff have any questions, they may direct them to Marilyn Powers, 

Office of Air Program Planning, at (215) 814-2308. She is the principal contact for this 

rulemaking. 

Sincerely, f\ 

-:])I Cll\CLf_fjl/\J\._,,/1 

Diana Esher, Director 

Air Protection Division 

cc: Tad Abum, Director, Air and Radiation Management Administration 

Customer Service Hotline: 1-800-438-2474 

SIP Submitted by: 

Date Submitted: 

SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST 

(in accordance with 40 CFR Part 51 - App. V) 

Maryland Department of the Environmental 

December 23,2013 

Subject: Redesignation Request and Maintenance Plan for Washington County, Maryland (the Maryland Portion of the 

Hagerstown-Martinsburg MD,WV 1997Annual Fine Particulate Matter (PM2.5) Nonattainment Area) 

Completeness Review 

Completed by: Marilyn Powers 

Date Completed: January 23, 2014 

Administrative Materials ACCEPTABLE 

I EPA REQUIREMENT I STATE SUBMITTAL I(X) I 

1. A formal letter of submittal from the Governor or his 1. Submittal letter dated December 23, 2013 from Maryland X 

designee, requesting EPA approval ofthe plan or revision Department of the Environment (MDE) Secretary Robert M. 

thereof. Summers to EPA Region 3 Regional Administrator Shawn M 

Garvin. Submittal letter was received on December 30, 2013. 

2. Evidence that the State has adopted the plan in the State code 2. Not applicable. (Not a regulatory change - the submittal is 

or body of regulations; or issued the permit, order, consent a request for redesignation, accompanied by a maintenance 

agreement in final form. That evidence shall include the date plan, and a request for approval of the attainment year 

of adoption or final issuance as well as the effective date of the inventory). 

plan, if different from the adoption/issuance date. 

3. Evidence that the State has the necessary legal authority 3. Section 4 of the Maintenance Plan states: "The state has the X 

under State law to adopt and implement the plan. legal authority to implement and enforce specified measures 

necessary to attain and maintain the NAAQS". Maryland 

Environmental Article, Title 2, Annotated Code of Maryland 

Section 2-103 provides the authority related to ambient air 

quality in the State, and Sections 2-301 o 2-303 pertain to the 

authorities for adopting and implementation of rules. 
4. A copy of actual regulation, or document submitted for 4. The submitted document entitled "Washington County, MD 

approval and incorporation by reference into the plan, including Nonattainment Area PM2.5 Redesignation Request and 

indication of the changes made to the existing approved plan, Maintenance Plan" dated May 28, 2013, includes a copy of the 

where applicable. The submittal shall be a copy of the official maintenance plan submitted by MDE for approval and 

State regulation/document signed, stamped, dated by the incorporation by reference into the Maryland SIP. 

appropriate State official indicating that it is fully enforceable 

by the State. The effective date of the regulation/document 

shall, whenever possible, be indicated in the document itself. 

5. Evidence that the State followed all of the procedural 5. The submittal includes documentation showing that MDE X 

requirements of the State's laws and constitution in conducting followed State procedural and administrative requirements in 

and completing the adoption/issuance of the plan. issuing the plan. ' . 

6. Evidence that public notice was given of the proposed 6. The submittal includes a copy of the notice of public hearing X 

change consistent with procedures approved by EPA, including and public comment period published in the Maryland Register 

the date of publication of such notice. on September 2, 2013, and posted on the MDE webpage from 

September 6, 2013 to October 9, 2013. 

7. Certification that public hearings were held in accordance 7. The submittal letter states that MDE followed all required X 

with the information provided in the public notice and the administrative procedures throughout the hearing process. The 

State's laws and constitution, if applicable. submittal includes documentation showing that the public 

hearing was held in accordance with the public notice. 

8. Compilation of public comments and the State's response 8. The submittal includes a compilation of public comments X 

thereto. and MDE's responses to the comments. 
I EPA REQUIREMENT I STATE SUBMITTAL I I 

1. Identification of all regulated pollutants affected by the plan. 

2. Identification of the locations of affected sources including 

the EPA attainment/nonattainment designation of the locations 

and the status of the attainment plan for the affected area(s). 

3. Quantification of the changes in plan allowable .emissions 

from the affected sources; estimates of changes in current 

actual emissions from affected sources or, where appropriate, 

quantification of changes in actual emissions from affected 

sources through calculations of the differences between certain 

baseline levels and allowable emissions anticipated as a result 

of the revision. 

4. The State's demonstration that the national ambient air 

quality standards, prevention of significant deterioration 

increments, reasonable further progress demonstration, and 

visibility, as applicable, are protected if the plan is approved 

and implemented. 

5. Modeling information required to support the proposed 

revision, including input data, output data, models used, 

ambient monitoring data used, meteorological data used, 

justification for use of offsite data (where used), modes of 

1. Chapter 4 of the Maintenance Plan indicates that nitrogen 

oxides (NOx), sulfur oxides (S02), and PM2.5 are the pollutants 

affected by the plan. MDE's review of volatile organic 

compounds (VOC), and ammonia (NH3) indicated that 

emissions of these precursors are insignificant (see Appendix 

G of the submittal.) 

2. Washington County, Maryland (the Maryland portion of 

the Hagerstown-Martinsburg MD, WV 1997 PM2.5 

Nonattainment Area (Area)) 

3. The submittal provides 2007 actual emissions from point, 

area, nonroad, and on-road source categories as the attainment 

year inventory, which may not be exceeded during the period 

of the maintenance plan. Projection inventories were 

calculated to show that the attainment year emissions level will 

be below 2007 levels. 

4. MDE submitted a demonstration that shows that emissions 

of PM2.5 and its precursors will not exceed the level of the 

attainment inventory during the period of the Maintenance 

Plan. Projected interim year 2017 and end year 2025 

emissions inventories, based on permanent and enforceable 

measures, are below the 2007 inventory, which assures the 

National Ambient Air Quality Standard (NAAQS) is 

maintained. 

5. Not applicable. MDE used the emissions inventory 

approach to support the revision. 

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X 

X 

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models used, assumptions, and other information relevant to 

the determination of adequacy of the modeling analysis. 

6. Evidence, where necessary, that emission limitations are 

!based on continuous emission reduction technology. 

7. Evidence that the plan contains emission limitations, work 

practice standards and recordkeeping/reporting requirements, 

where necessary, to ensure emission levels. 

8. Compliance/enforcement strategies, including how 

compliance will be determined in practice. 

9. Special economic and technological justifications required 

by any applicable EPA policies. (If a policy is not appropriate, 

explain why.) 

10. A Section 107 request must be accompanied by .a 

maintenance plan demonstrating maintenance to the relevant 

NAAQS for at least 10 years after redesignation. 

6. Not applicable. 

7. The plan includes emission limitations based on the 2007 1 X 

attainment inventory, and includes periodic emissions 

inventory updates to track the progress of the maintenance 

demonstration. The projected emissions inventories are based 

on permanent and enforceable measures. 

8. The Maintenance Plan includes: 1 X 

a) A commitment that MDE, once the Area is redesignated, 

will continue to operate its PM2.5 monitoring network to verify 

maintenance; 

b) Provisions for future updates of the inventory to enable 

tracking of emissions levels, including an annual emissions 

statement from major sources; and 

c) Identification of and an implementation schedule for 

contingency measures if a future inventory estimate indicates 

emissions greater than the 2007 inventories for a source 

category, or if a NAAQS violation occurs after redesignation. 

9. Not applicable 

10. The redesignation request was accompanied by a 

Maintenance Plan that shows maintenance of the 1997 PM2.5 

NAAQS for 10 years after redesignation (through 2025). 

X