UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION Ill 1650 Arch Street Philadelphia, Pennsylvania 19103-2029



### The Honorable Robert M. Summers, Secretary Maryland Department ofthe Environment 1800 Washington Boulevard Baltimore, Maryland 21230 Dear Secretary Summers: 

## fEB 10

## 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 ofthe Environment (MDE). This SIP revision consists ofa redesignation request and maintenance plan for the Maryland portion ofthe 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 ofProposed Rulemaking (NPR).

Ifmembers ofyour staffhave any questions, they may direct them to Marilyn Powers, Office ofAir Program Planning, at (215) 814-2308. She is the principal contact for this rulemaking

. Sincerely, f\ 

# -:])ICll\CLf_fjl/\J\._,,/1 Diana Esher, Director Air Protection Division

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

CustomerServiceHotline: 1-800-438-2474

### SIP Submitted by: Date Submitted: SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST 

### (in accordance with 40 CFRPart 51

- App. V) Maryland Department ofthe Environmental December 23,2013 Subject: Redesignation Request and Maintenance Plan for Washington County, Maryland (the Maryland Portion ofthe 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 ofsubmittal from the Governor or his 1. 

### Submittal letter dated December 23, 2013 from Maryland X 

### designee, requesting EPA approval ofthe plan orrevision Department ofthe 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 inthe State code 2. Not applicable. (Not a regulatory change

- the submittal is or body ofregulations; 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 ofthe attainment year ofadoption or final issuance as well as the effective date ofthe inventory). plan, ifdifferent from the adoption/issuance date. 3. Evidence that the State has the necessary legal authority 3. Section 4 ofthe Maintenance Plan states: "The state has the X 

### under State lawto 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 ofMaryland 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 ofrules.4. A copy ofactual 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 ofthe changes made to the existing approved plan, Maintenance Plan" dated May 28, 2013, includes a copy ofthe where applicable. The submittal shall be a copy ofthe 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 ofthe regulation/document shall, whenever possible, be indicated in the document itself. 5. Evidence that the State followed all ofthe procedural 5. The submittal includes documentation showing that MDE X requirements ofthe State's laws and constitution in conducting followed State procedural and administrative requirements in and completing the adoption/issuance ofthe plan. issuing the plan. '

. 6. Evidence that public notice was given ofthe proposed 6. The submittal includes a copy ofthe notice ofpublic hearing X change consistent with procedures approved by EPA, including and public comment period published in the Maryland Register the date ofpublication ofsuchnotice. on September 2, 2013, and posted onthe MDE webpage from September 6, 2013 to October 9, 2013. 7. Certificationthat public hearings were held in accordance 7. The submittal letter states that MDE followed all required X withthe informationprovided in the public notice and the administrative procedures throughout the hearing process. The State's laws and constitution, ifapplicable. submittal includes documentation showing that the public hearing was held in accordance with the public notice. 8. Compilation ofpublic comments and the State's response 8. The submittal includes a compilation ofpublic comments X thereto. and MDE's responses to the comments.

# I EPAREQUIREMENT 

# I STATE SUBMITTAL 

# I I

1. Identification ofall regulated pollutants affected by the plan.

2. Identification ofthe locations ofaffected sources including the EPA attainment/nonattainment designation ofthe locations and the status ofthe attainment plan for the affected area(s).

3. Quantification ofthe changes inplan allowable .emissions from the affected sources; estimates ofchanges in current actual emissions from affected sources or, where appropriate, quantification ofchanges in actual emissions from affected sources through calculations ofthe differences between certain baseline levels and allowable emissions anticipated as a result ofthe revision. 4. The State's demonstration that the national ambient air quality standards, prevention ofsignificant deterioration increments, reasonable further progress demonstration, and visibility, as applicable, are protected ifthe 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, justificationfor use ofoffsite data (where used), modes of 1. Chapter 4 ofthe Maintenance Plan indicates that nitrogen oxides (NOx), sulfur oxides (S02), and PM2.5 are the pollutants affected by the plan. MDE's review ofvolatile organic compounds (VOC), and ammonia (NH3) indicated that emissions ofthese precursors are insignificant (see Appendix G ofthe 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 ofthe maintenance plan. Projection inventories were calculatedto showthatthe attainment year emissions level will be below 

### 2007 levels.
4. MDE submitted a demonstration that shows that emissions ofPM2.5 and its precursors will not exceed the level ofthe attainment inventory during the period ofthe Maintenance Plan. Projected interim year 

### 2017 and end year 

### 2025 emissions inventories, based onpermanent and enforceable measures, are belowthe 

### 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. X

X



### X

Xmodels used, assumptions, and other information relevant to the determination ofadequacy ofthe 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 technologicaljustifications required by any applicable EPA policies. (Ifa 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 onthe 2007 1 X attainment inventory, and includes periodic emissions inventory updates to track the progress ofthe 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 f or future updates ofthe inventory to enable tracking ofemissions levels, including an annual emissions statement from major sources; and c) Identification ofand an implementation schedule for contingency measures ifa future inventory estimate indicates emissions greater than the 2007 inventories for a source category, or ifa NAAQS violation occurs after redesignation. 9. Not applicable

10

. The redesignation request was accompanied by a Maintenance Plan that shows maintenance ofthe 1997 PM2.5 NAAQS for 10 years after redesignation (through 2025). X