SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST 

 (in accordance with 40 CFR Part 51 - App. V) SIP Submitted by: Maryland Department of the Environmental Date Submitted: December 12, 2013 Subject: Redesignation Request and Maintenance Plan for the Baltimore 1997Annual Fine Particul

Nonattainment Area 

Completeness Review Completed by: Marilyn Powers Date Completed: February 20, 2014 Administrative Materials 

EPA REQUIREMENT STATE SUBMITTAL 

1. A formal letter of submittal from the Governor or his designee, requesting EPA approval of the plan or revision thereof. 

1. Submittal letter dated December 12, 2013 froDepartment of the Environment (MDE) SecretarSummers to EPA Region 3 Regional AdministrGarvin. Submittal letter was received on Decem

2. Evidence that the State has adopted the plan in the State code or body of regulations; or issued the permit, order, consent agreement in final form. That evidence shall include the date of adoption or final issuance as well as the effective date of the plan, if different from the adoption/issuance date. 

2. Not applicable. (Not a regulatory change - ta request for redesignation, accompanied by a mplan, and a request for approval of the attainmeninventory). 

3. Evidence that the State has the necessary legal authority under State law to adopt and implement the plan. 

3. Section 4 of the Maintenance Plan states: “Tlegal authority to implement and enforce specifinecessary to attain and maintain the NAAQS”. Environmental Article, Title 2, Annotated Code Section 2-103 provides the authority related to aquality in the State, and Sections 2-301 o 2-303 authorities for adopting and implementation of r
4. A copy of actual regulation, or document submitted for 

approval and incorporation by reference into the plan, including indication of the changes made to the existing approved plan, where applicable. The submittal shall be a copy of the official State regulation/document signed, stamped, dated by the 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. 

4. The submitted document entitled “Baltimore NArea PM2.5 Redesignation Request and Mainten

dated May 28, 2013, includes a copy of the mainsubmitted by MDE for approval and incorporatiinto the Maryland SIP. 

5. Evidence that the State followed all of the procedural requirements of the State's laws and constitution in conducting and completing the adoption/issuance of the plan. 

5. The submittal includes documentation showifollowed State procedural and administrative reqissuing the plan. 

6. Evidence that public notice was given of the proposed change consistent with procedures approved 

by EPA, including 

the date of publication of such notice. 

6. The submittal includes a copy of the notice ohearing and public comment period published in Register on September 20, 2013, and posted on webpage from September 6, 2013 to October 9, 

7. Certification that public hearings were held in accordance with the information provided in the public notice and the State's laws and constitution, if applicable. 

7. The submittal letter states that MDE followed administrative procedures throughout the hearinsubmittal includes documentation showing that thearing was held in accordance with the public n

8. Compilation of public comments and the State's response thereto. 

8. The submittal includes a compilation of publand MDE’s responses to the comments. 
EPA REQUIREMENT STATE SUBMITTAL 

1. Identification of all regulated pollutants affected by the plan. 1. Section 4 of the Maintenance Plan indicates t

oxides (NOx), sulfur oxides (SO2), and PM2.5 ar

affected by the plan. MDE’s review of volatile compounds (VOC), and ammonia (NH3) indicat

emissions of these precursors are insignificant (Athe submittal.) 

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). 

2. Anne Arundel County, Baltimore County, CaHarford County, Howard County, and Baltimore 

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. 

3. The submittal provides 2007 actual emissionarea, nonroad, and on-road source categories as year inventory, which may not be exceeded duriof the maintenance plan. Projection inventories calculated to show that the attainment year emisbe below 2007 levels (sections 4.11 and 4.2). 

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. 

4. MDE submitted a demonstration that shows tof PM2.5 and its precursors will not exceed the le

attainment inventory during the period of the MPlan. Projected interim year 2017 and end year emissions inventories, based on permanent and emeasures, are below the 2007 inventory, which National Ambient Air Quality Standard (NAAQmaintained (section 4.3). 

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 models used, assumptions, and other information relevant to 

5. Not applicable. MDE used the emissions invapproach to support the revision. 
the determination of adequacy of the modeling analysis. 

6. Evidence, where necessary, that emission limitations are based on continuous emission reduction technology. 

6. Not applicable. 

7. Evidence that the plan contains emission limitations, work practice standards and recordkeeping/reporting requirements, where necessary, to ensure emission levels. 

7. The plan includes emission limitations based attainment inventory, and includes periodic emiinventory updates to track the progress of the mademonstration. The projected emissions inventoon permanent and enforceable measures. 

8. Compliance/enforcement strategies, including how compliance will be determined in practice. 

8. The Maintenance Plan includes: a) A commitment that MDE, once the Area is rewill continue to operate its PM2.5 monitoring net

maintenance (section 4.4); b) Provisions for future updates of the inventory tracking of emissions levels, including an annuastatement from major sources (section 4.5); and c) Identification of and an implementation schedterm and long term contingency measures if a fuestimate indicates emissions greater than the 200for a source category, or if a NAAQS violation oredesignation (section 4.7). 

9. Special economic and technological justifications required by any applicable EPA policies. (If a policy is not appropriate, explain why.) 

9. Not applicable 

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. 

10. The redesignation request was accompanied Maintenance Plan that shows maintenance of the NAAQS for 10 years after redesignation (throug