SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST(in accordance with 40 CFR Part 51 - App. V)SIP Submitted by: Maryland Department of the EnvironmentalDate Submitted: December 12, 2013Subject: Redesignation Request and Maintenance Planfor the Baltimore 1997Annual Fine Particulate Matter (PM2.5)Nonattainment AreaCompleteness ReviewCompleted by: Marilyn PowersDate Completed: February 20, 2014Administrative MaterialsACCEPTABLEEPA REQUIREMENTSTATE SUBMITTAL(X)1. A formal letter of submittal from the Governor or hisdesignee, requesting EPA approval of the plan or revisionthereof.1. Submittal letter dated December 12, 2013 from MarylandDepartment of the Environment (MDE) Secretary Robert M.Summers to EPA Region 3 Regional Administrator Shawn MGarvin. Submittal letter was received on December 23, 2013.X2. Evidence that the State has adopted the plan in the State codeor body of regulations; or issued the permit, order, consentagreement in final form. That evidence shall include the dateof adoption or final issuance as well as the effective date of theplan, if different from the adoption/issuance date.2. Not applicable. (Not a regulatory change - the submittal isa request for redesignation, accompanied by a maintenanceplan, and a request for approval of the attainment yearinventory).3. Evidence that the State has the necessary legal authorityunder State law to adopt and implement the plan.3. Section 4 of the Maintenance Plan states: “The state has thelegal authority to implement and enforce specified measuresnecessary to attain and maintain the NAAQS”. MarylandEnvironmental Article, Title 2, Annotated Code of MarylandSection 2-103 provides the authority related to ambient airquality in the State, and Sections 2-301 o 2-303 pertain to theauthorities for adopting and implementation of rules.X4. A copy of actual regulation, or document submitted forapproval and incorporation by reference into the plan,including indication of the changes made to the existingapproved plan, where applicable. The submittal shall be a copyof the official State regulation/document signed, stamped,dated by the appropriate State official indicating that it is fullyenforceable by the State. The effective date of theregulation/document shall, whenever possible, be indicated inthe document itself.4. The submitted document entitled “Baltimore NonattainmentArea PM2.5Redesignation Request and Maintenance Plan”dated May 28, 2013, includes a copy of the maintenance plansubmitted by MDE for approval and incorporation by referenceinto the Maryland SIP.X5. Evidence that the State followed all of the proceduralrequirements of the State's laws and constitution in conductingand completing the adoption/issuance of the plan.5. The submittal includes documentation showing that MDEfollowed State procedural and administrative requirements inissuing the plan.X6. Evidence that public notice was given of the proposedchange consistent with procedures approvedby EPA, includingthe date of publication of such notice.6. The submittal includes a copy of the notice of publichearing and public comment period published in the MarylandRegister on September 20, 2013, and posted on the MDEwebpage from September 6, 2013 to October 9, 2013.X7. Certification that public hearings were held in accordancewith the information provided in the public notice and theState's laws and constitution, if applicable.7. The submittal letter states that MDE followed all requiredadministrative procedures throughout the hearing process. Thesubmittal includes documentation showing that the publichearing was held in accordance with the public notice.X8. Compilation of public comments and the State's responsethereto.8. The submittal includes a compilation of public commentsand MDE’s responses to the comments.XEPA REQUIREMENTSTATE SUBMITTAL1. Identification of all regulated pollutants affected by the plan.1. Section 4 of the Maintenance Plan indicates that nitrogenoxides (NOx), sulfur oxides (SO2), and PM2.5are the pollutantsaffected by the plan. MDE’s review of volatile organiccompounds (VOC), and ammonia (NH3) indicated thatemissions of these precursors are insignificant (Appendix G ofthe submittal.)X2. Identification of the locations of affected sources includingthe EPA attainment/nonattainment designation of the locationsand the status of the attainment plan for the affected area(s).2. Anne Arundel County, Baltimore County, Carroll County,Harford County, Howard County, and Baltimore CityX3. Quantification of the changes in plan allowable emissionsfrom the affected sources; estimates of changes in currentactual emissions from affected sources or, where appropriate,quantification of changes in actual emissions from affectedsources through calculations of the differences between certainbaseline levels and allowable emissions anticipated as a resultof the revision.3. The submittal provides 2007 actual emissions from point,area, nonroad, and on-road source categories as the attainmentyear inventory, which may not be exceeded during the periodof the maintenance plan. Projection inventories werecalculated to show that the attainment year emissions level willbe below 2007 levels (sections 4.11 and 4.2).X4. The State's demonstration that the national ambient airquality standards, prevention of significant deteriorationincrements, reasonable further progress demonstration, andvisibility, as applicable, are protected if the plan is approvedand implemented.4. MDE submitted a demonstration that shows that emissionsof PM2.5and its precursors will not exceed the level of theattainment inventory during the period of the MaintenancePlan. Projected interim year 2017 and end year 2025emissions inventories, based on permanent and enforceablemeasures, are below the 2007 inventory, which assures theNational Ambient Air Quality Standard (NAAQS) ismaintained (section 4.3).X5. Modeling information required to support the proposedrevision, including input data, output data, models used,ambient monitoring data used, meteorological data used,justification for use of offsite data (where used), modes ofmodels used, assumptions, and other information relevant to5. Not applicable. MDE used the emissions inventoryapproach to support the revision.the determination of adequacy of the modeling analysis.6. Evidence, where necessary, that emission limitations arebased on continuous emission reduction technology.6. Not applicable.7. Evidence that the plan contains emission limitations, workpractice standards and recordkeeping/reporting requirements,where necessary, to ensure emission levels.7. The plan includes emission limitations based on the 2007attainment inventory, and includes periodic emissionsinventory updates to track the progress of the maintenancedemonstration. The projected emissions inventories are basedon permanent and enforceable measures.X8. Compliance/enforcement strategies, including howcompliance will be determined in practice.8. The Maintenance Plan includes:a) A commitment that MDE, once the Area is redesignated,will continue to operate its PM2.5monitoring network to verifymaintenance (section 4.4);b) Provisions for future updates of the inventory to enabletracking of emissions levels, including an annual emissionsstatement from major sources (section 4.5); andc) Identification of and an implementation schedule for nearterm and long term contingency measures if a future inventoryestimate indicates emissions greater than the 2007 inventoriesfor a source category, or if a NAAQS violation occurs afterredesignation (section 4.7).X9. Special economic and technological justifications requiredby any applicable EPA policies. (If a policy is not appropriate,explain why.)9. Not applicable10. A Section 107 request must be accompanied by amaintenance plan demonstrating maintenance to the relevantNAAQS for at least 10 years after redesignation.10. The redesignation request was accompanied by aMaintenance Plan that shows maintenance of the 1997 PM2.5NAAQS for 10 years after redesignation (through 2025).X