Washington DC-MD-VA 1997 PM2.5 Redesignation

Request

Prepared by:

Metropolitan Washington Council of Governments

for the 

District Department of the Environment

Maryland Department of the Environment

Virginia Department of Environmental Quality

on behalf of the

Metropolitan Washington Air Quality Committee

May 22, 2013
Washington, DC-MD-VA PM2.5 NAA Redesignation Request, May 22, 2013

Table of Contents

1. Introduction............................................................................................................................. 1

2. Background............................................................................................................................. 1

2.1 Health Effects................................................................................................................... 1

2.2 Washington DC-MD-VA Nonattainment Designation.................................................... 1

3. USEPA Requirements for Redesignation ............................................................................... 4

3.1 NAAQS Compliance........................................................................................................ 4

3.1.1 USEPA Requirements............................................................................................... 4

3.1.2 Washington DC-MD-VA Approach ......................................................................... 4

3.2 Permanent and Enforceable Emission Reductions........................................................... 9

3.2.1 USEPA Requirements............................................................................................... 9

3.2.2 Washington DC-MD-VA Approach ....................................................................... 10

3.3 SIP Completeness........................................................................................................... 13

3.3.1 USEPA Requirements............................................................................................. 13

3.3.2 Washington DC-MD-VA Approach ....................................................................... 14

3.4 Maintenance Plan ........................................................................................................... 15

3.4.1 USEPA Requirements............................................................................................. 15

3.4.2 Washington DC-MD-VA Approach ....................................................................... 15

List of Figures 

Figure 2-1: Washington DC-MD-VA 1997 PM2.5 NAAQS Nonattainment Area ........................ 3

Figure 3-1: Washington DC-MD-VA PM2.5 Monitoring Sites...................................................... 6

Figure 3-2: Washington DC-MD-VA 24-Hour PM2.5 Data Trends............................................... 8

Figure 3-3: Washington DC-MD-VA Annual PM2.5 Data Trends ................................................ 9

List of Tables

Table 2-1: Washington DC-MD-VA Nonattainment Area Jurisdictions With FIPS Codes ......... 2

Table 3-1: Washington DC-MD-VA 24-Hour PM2.5 Design Values............................................ 7

Table 3-2: Washington DC-MD-VA Annual PM2.5 Design Values.............................................. 7

Table 3-3: On-Road Emission Reductions for the Washington DC-MD-VA Area, 2002-2007 . 11

Table 3-4: Possum Point Power Station Reductions, 2002-2007 ................................................ 12

Table 3-5: Washington DC-MD-VA Mirant System 2002-2007 NOX Reductions .................... 13

List of Appendices

Appendix C1: Technical support document for the development of onroad mobile emissions 

inventories for 2002, 2007, 2017, and 2025 (Washington, DC-MD-VA PM2.5 Nonattainment 

Area)

Appendix C2: MOVES Input / Output Files (Available on a CD on request)

Appendix E: Notices and Public Comments and Responses
Washington, DC-MD-VA PM2.5 NAA Redesignation Request, May 22, 2013 1

1. Introduction

The District of Columbia, the State of Maryland, and the Commonwealth of Virginia

request that the United States Environmental Protection Agency (USEPA) redesignate the 

Washington DC-MD-VA 1997 fine particulate (PM2.5) nonattainment area to attainment for this 

standard pursuant to the provisions under § 107 of the federal Clean Air Act (CAA). Since the 

designations for the National Ambient Air Quality Standards (NAAQS) for this pollutant were 

published (70 FR 944, 1/5/2005), the area’s PM2.5 air quality has improved due to permanent and 

enforceable emission reductions. Air quality in the area is significantly better than required by 

this standard. Due to the improvement in PM2.5 air quality, the Washington DC-MD-VA

nonattainment area is currently operating under a clean data determination (74 FR 1146, 

1/12/2009). The District of Columbia, the State of Maryland, and the Commonwealth of 

Virginia are also requesting that USEPA concurrently approve, as a revision to the state 

implementation plan (SIP) for each state, the related § 175A maintenance plan. This plan 

ensures that good PM2.5 air quality will be maintained through 2025.

2. Background

2.1 Health Effects

PM2.5, also known as fine particulate matter or fine particles, is defined as any airborne 

particle of solid or liquid matter that is less than or equal to 2.5 micrometers in diameter. PM2.5 is 

not a single pollutant but a sum of all pollutants that have diameters less than 2.5 micrometers, 

which is 1/30th the diameter of a human hair. 

Sources of PM2.5 and PM2.5 precursors include, most significantly, coal-fired power 

plants and other combustion sources, fires, emissions from motor vehicles, windblown dust, and 

natural emissions from trees and the oceans. These sources can be divided up into two types of 

sources, primary and secondary. Primary sources directly emit fine particulate matter into the 

atmosphere without any chemical change occurring to the pollutant. Secondary sources are 

sources from which precursor chemical species are released into the atmosphere and then react 

with other chemical species in the atmosphere to create fine particulate matter. Some species 

which comprise fine particulate matter are sulfates, ammonium nitrate, soot, sea salt, organic 

carbon, and metals (crustal metals, transitional metals, and potassium).

Exposure to high levels of PM2.5 adversely affects human health. The main impacts of 

PM2.5 on human health are on the respiratory system and the cardiovascular system. Children, 

the elderly, and individuals with pre-existing pulmonary or cardiac disease are the most 

susceptible to PM2.5 pollution. Complications that can arise from exposure to PM2.5 include 

decreased lung function, chronic bronchitis, respiratory symptoms such as asthma attacks and 

difficulty breathing, nonfatal heart attacks, irregular heartbeat, and premature death in 

individuals with pulmonary or cardiac disease.

2.2 Washington DC-MD-VA Nonattainment Designation

The CAA requires each state with areas failing to meet the 1997 PM2.5 NAAQS to develop 

SIPs to expeditiously attain and maintain the standards. The USEPA revised the NAAQS for 
Washington, DC-MD-VA PM2.5 NAA Redesignation Request, May 22, 2013 2

particulate matter in July 1997 and established primary (health-based) annual and 24-hour 

standards for PM2.5 (62 FR 38652, 7/18/1997). The annual standard was set at 15.0 micrograms 

per cubic meter (μg/m3), based on the 3-year average of annual mean PM2.5 concentrations and 

the 24-hour standard was set at 65 μg/m3, based on the 3-year average of the 98th percentile of 

24-hour concentrations. 

On December 17, 2004, the USEPA administrator signed the final rule regarding the initial 

PM2.5 nonattainment areas designations for the PM2.5 standards across the country. The final rule 

became effective on April 5, 2005 (70 FR 944, 1/5/2005). The Washington DC-MD-VA area 

was originally designated nonattainment for the 1997 PM2.5 NAAQS based on air quality data 

showing that the area did not meet the 15.0 μg/m3annual standard. Unlike Subpart 2 of the CAA 

that defined five ozone nonattainment classifications for the areas that exceed the NAAQS based 

on the severity of the ozone levels, PM2.5 nonattainment designations are simply labeled 

“nonattainment.” Within three years of the effective date of the designations (April 5, 2008), the 

CAA required states with PM2.5 nonattainment areas to submit an attainment plan detailing how 

the PM2.5 standards will be attained by April 5, 2010. States within the Washington DC-MD-VA

area submitted these attainment plans in a timely manner. 

The area designated nonattainment for the 1997 PM2.5 NAAQS is defined in Table 2-1 and 

depicted in Figure 2-1.

Table 2-1: Washington DC-MD-VA Nonattainment Area Jurisdictions With FIPS Codes1

Maryland Jurisdictions Virginia Jurisdictions

Charles County (24-017) Fairfax County (51-059)

Frederick County (24-021) Prince William County (51-153)

Montgomery County (24-031) Arlington County (51-013)

Prince Georges County (24-033) Loudon County (51-107)

City of Fairfax (51-600)

City of Falls Church (51-610)

City of Manassas (51-683)

City of Manassas Park (51-685)

Washington D.C. (11-001) City of Alexandria (51-510)

 

1

FIPS Code - Federal Information Processing Standard Code
Washington, DC-MD-VA PM2.5 NAA Redesignation Request, May 22, 2013 3

Figure 2-1: Washington DC-MD-VA 1997 PM2.5 NAAQS Nonattainment Area
Washington, DC-MD-VA PM2.5 NAA Redesignation Request, May 22, 2013 4

3. USEPA Requirements for Redesignation

The CAA provides a process whereby a state may petition USEPA to redesignate a 

nonattainment area as attainment. The criteria for redesignating a nonattainment area to 

attainment are as follows:

 The request must contain a determination that the NAAQS has been attained.

 The request must contain a showing that the improvement in air quality is due to 

permanent and enforceable reductions in emissions.

 The applicable implementation plan must be fully approved by USEPA under § 110(k) of 

the CAA, and the redesignation request must contain a determination that the state meets 

all applicable requirements for the area under § 110 and Part D.

 A maintenance plan, including contingency measures, for the area under § 175A of the 

Act must be fully approved.

This document addresses each of these requirements and provides additional information 

to support continued compliance with the 1997 PM2.5 NAAQS. USEPA has published detailed 

guidance in a memorandum from John Calcagni, Director, Air Quality Management Division, 

entitled Procedures for Processing Requests to Redesignate Areas to Attainment (redesignation 

guidance), issued September 4, 1992, to Regional Air Directors. 40 CFR Part 51, Subpart Z, 

entitled Provisions for Implementation of PM2.5 National Ambient Air Quality Standards

(implementation rule) provides additional information. The District of Columbia, the State of 

Maryland, and the Commonwealth of Virginia have based this redesignation request and its 

associated maintenance plan on the redesignation guidance and the implementation rule,

supplemented with additional guidance received from staff of USEPA Region III.

3.1 NAAQS Compliance

3.1.1 USEPA Requirements

The NAAQS compliance demonstration should rely upon on ambient air quality data. 

The data that are used to demonstrate attainment should be the product of ambient monitoring 

that is representative of the area of highest concentration. Additionally, the data should be 

collected and quality-assured in accordance with 40 CFR Part 58 and recorded in the Air Quality 

System (AQS) in order for it to be available to the public for review. 

3.1.2 Washington DC-MD-VA Approach

To determine whether or not a site is in compliance with the 1997 annual PM2.5 NAAQS, 

the three-year average of annual average PM2.5 concentrations must be calculated and compared 

to the standard of 15.0 μg/m3.

 Compliance with the 1997 24-hour NAAQS for PM2.5, which is 

set at 65 μg/m3, is determined by the three year average of the 98th percentile of each individual 

year’s 24-hour concentrations. For an area to be in compliance with the 1997 PM2.5 NAAQS, all 

sites within that area must be in compliance with the annual and 24-hour NAAQS. Even if there 

is only one station that is not in compliance, that one station makes the entire area a 

nonattainment area for that standard. 
Washington, DC-MD-VA PM2.5 NAA Redesignation Request, May 22, 2013 5

The Washington DC-MD-VA region’s federal reference monitors have demonstrated 

compliance with the 65 μg/m3daily standard since the inception of the PM2.5 monitoring 

programs within each state. The federal reference monitors have demonstrated compliance with 

the 15.0 μg/m3annual standard since 2005. The most recent design value for the 24-hour 

standard, based on 2009-2011 data, is 26 μg/m3, and the most recent design value for the annual 

standard, based on 2009-2011 data, is 10.8 μg/m3. 

Figure 3-1 shows the locations of the area’s PM2.5 monitors. Three PM2.5 speciation 

monitors also operate in this area. Two are located in the District of Columbia at the McMillan 

Reservoir and the Hains Point sites. One is located in Maryland at the Howard UniversityBeltsville site.

All PM2.5 ambient monitoring data through 2011 have been quality assured in accordance 

with 40 CFR 58.10, recorded in USEPA’s AQS, and made available for public review. The 

2005-2007 design value has been chosen as the attainment year for this area, and therefore the 

attainment year inventory used within this redesignation request and the § 175A maintenance 

plan is based on year 2007. 

The states commit to continuing the operation of an appropriate PM2.5 air quality 

monitoring network to verify the maintenance of the attainment status. 

Table 3-1 and Table 3-2 show the design values for monitoring sites in the Washington 

DC-MD-VA area.
Washington, DC-MD-VA PM2.5 NAA Redesignation Request, May 22, 2013 6

Figure 3-1: Washington DC-MD-VA PM2.5 Monitoring Sites
Washington, DC-MD-VA PM2.5 NAA Redesignation Request, May 22, 2013 7

Table 3-1: Washington DC-MD-VA 24-Hour PM2.5 Design Values

Site 1999-

2001

2000-

2002

2001-

2003

2002-

2004

2003-

2005

2004-

2006

2005-

2007

2006-

2008

2007-

2009

2008-

2010

2009-

2011

11-001-0041

River Terrace, DC 41 45 44 42 38 37 35 32 29 27 *

11-001-0042

Hains Point, DC 39 38 37 37 37 35 33 31 28 26 *

11-001-0043

McMillan Reservoir, DC 40 41 40 37 35 34 34 32 29 26 *

24-031-3001

Rockville, MD * 37 35 33 32 31 30 28 26 26 26

24-033-0025

Bladensburg, MD# * * * * * * * * 28 25 23

24-033-0030

HU-Beltsville, MD * * * * * * 32 30 25 25 24

24-033-8003

Equestrian Center, MD * * * 39 * 35 32 31 26 22 20

51-013-0020

Aurora Hills, VA 36 37 38 37 36 34 32 30 27 * *

51-059-0030

Franconia, VA * 36 * 35 35 35 34 31 28 25 24

51-107-1005

Ashburn, VA 36 35 34 34 36 35 33 28 24 21 20

51-510-0009

Alexandria, VA * * * * * * * * * * *

*Monitor not operating or design value labeled incomplete. # Bladensburg monitor stopped operating on December 30, 2011.

Table 3-2: Washington DC-MD-VA Annual PM2.5 Design Values

Site 1999-

2001

2000-

2002

2001-

2003

2002-

2004

2003-

2005

2004-

2006

2005-

2007

2006-

2008

2007-

2009

2008-

2010

2009-

2011

11-001-0041

River Terrace, DC 16.5 16.4 15.8 15.1 14.8 14.4 14.0 13.0 12.0 11.2 10.6

11-001-0042

Hains Point, DC * 15.3 14.7 14.5 14.5 14.5 14.2 13.1 12.1 11.2 10.5

11-001-0043

McMillan Reservoir, DC 15.7 15.6 15.2 14.7 14.4 14.0 13.5 12.5 11.6 10.8 10.3

24-031-3001

Rockville, MD * 13.4 12.6 12.5 12.7 12.5 12.2 11.4 10.7 10.3 10.2

24-033-0025

Bladensburg, MD# * * * * * * * * 12.4 11.5 10.8

24-033-0030

HU-Beltsville, MD * * * * * * 12.2 11.4 10.5 10.0 9.9

24-033-8003

Equestrian Center, MD * * * * 13.2 13.1 12.8 11.9 10.8 9.9 9.1

51-013-0020

Aurora Hills, VA * 14.8 14.6 14.5 14.6 14.2 14.0 12.9 11.9 * *

51-059-0030

Franconia, VA * * * 13.4 13.6 13.4 13.0 12.1 11.1 10.3 9.6

51-107-1005

Ashburn, VA * 13.8 13.6 13.5 13.9 13.6 13.2 12.2 11.2 10.3 9.5

51-510-0009

Alexandria, VA * * * * * * * * * * *

*Monitor not operating or design value labeled incomplete. # Bladensburg monitor stopped operating on December 30, 2011.
Washington, DC-MD-VA PM2.5 NAA Redesignation Request, May 22, 2013 8

Figure 3-2 illustrates the steady decrease in the 24-hour PM2.5 design value. Since 2006, 

the PM2.5 design value for the Washington DC-MD-VA nonattainment area has decreased an 

average of 2.2 μg/m3per year. This equates to a 30 percent drop in the 24-hour PM2.5 design 

value over the last five years. Looking at the interval from 2001 to 2011, the 24-hour PM2.5

design value decreased 15 μg/m3over the ten year period, which is a 37 percent decrease in the 

PM2.5 design value since 2001.

Figure 3-3 shows a decreasing trend in the annual PM2.5 design value as well. For each 

year from 2001 to 2011, the annual PM2.5 design value decreased for the Washington DC-MDVA 1997 PM2.5 NAAQS nonattainment area. Over this time period, the annual PM2.5 design 

value has improved 5.7 μg/m3, a decrease of 35 percent since 2001. Since 2006, the annual 

PM2.5 design value has decreased 3.7 μg/m3over five years, an average decrease of 0.7 μg/m3per 

year.

Figure 3-2: Washington DC-MD-VA 24-Hour PM2.5 Data Trends

1 5

2 5

3 5

4 5

5 5

6 5

7 5

1999-2001 2000-2002 2001-2003 2002-2004 2003-2005 2004-2006 2005-2007 2006-2008 2007-2009 2008-2010 2009-2011 PM2.5 Concentrations in ug/m3

3 year period

24-Hour PM2.5 Design Value Trend

Washington, DC-MD-VA PM2.5 Nonattainment Area

110010041

110010042

110010043

240313001

240330025

240330030

240338003

510130020

510590030

511071005

Series12

2006 24-hour Standard = 35 μg/m3

1997 24-hour Standard = 65 μg/m3
Washington, DC-MD-VA PM2.5 NAA Redesignation Request, May 22, 2013 9

Figure 3-3: Washington DC-MD-VA Annual PM2.5 Data Trends

3.2 Permanent and Enforceable Emission Reductions

3.2.1 USEPA Requirements

As noted in § 107(d)(3)(E)(iii) and in the redesignation guidance, states must be able to 

reasonably attribute air quality improvements to emission reductions of precursors or direct 

PM2.5 that are permanent and enforceable. Attainment resulting from temporary reductions in 

emission rates (such as reduced production or shutdown due to temporary adverse economic 

conditions) or unusually favorable meteorological conditions does not qualify.

In making this showing, the state should estimate the percent reduction (from the year 

that was used to determine the design value for designation and classification) achieved from 

federal and state measures. Estimates should consider factors such as emission rates and 

production capacities in order to show that the improvements are the result of implemented 

controls. The analysis should assume that sources are operating at permitted levels (or historic 

peak levels), unless evidence is presented that such an assumption is unrealistic.

For this redesignation request and the associated maintenance plan, ammonia and volatile 

organic compounds (VOC) are precursors, however, they are not considered significant overall 

9.0

10.0

11.0

12.0

13.0

14.0

15.0

16.0

17.0

1999-2001 2000-2002 2001-2003 2002-2004 2003-2005 2004-2006 2005-2007 2006-2008 2007-2009 2008-2010 PM2.5 Concentrations in ug/m3

3 year period

Annual PM2.5 Design Value Trend

Washington, DC-MD-VA PM2.5 Nonattainment Area

110010041

110010042

110010043

240313001

240330025

240330030

240338003

510130020

510590030

511071005

1997 Annual Standard = 15.0 μg/m3
Washington, DC-MD-VA PM2.5 NAA Redesignation Request, May 22, 2013 10

contributors to PM2.5 air quality issues, as noted in the PM2.5 implementation rule at 40 CFR 

51.1002(c)(3). Therefore, the redesignation request and maintenance demonstration focus on 

SO2, PM2.5, and NOX. 

3.2.2 Washington DC-MD-VA Approach

Permanent and enforceable reductions of PM2.5, NOX, and SO2 from a variety of state and

federal measures have contributed to the attainment of the standard for fine particles. Measures 

that have contributed to fine particulate air quality improvement include, but are not limited to, a 

variety of on-road emissions control programs and federal consent decrees for specific power 

plants within the Washington DC-MD-VA area.

3.2.2.1 On-Road Emission Reduction Requirements

A variety of federal vehicle control programs have contributed to reduced on-road 

emissions of PM2.5, NOX, and SO2 in the Washington DC-MD-VA area between 2002 and 

2007.2 These programs include:

 Federal Tier 1 New Vehicle Emission and New Federal Evaporative Emission Standards: 

Under § 202, USEPA established federal motor vehicle emission standards (Tier I 

standards), which were phased in beginning with model year 1994 (40 CFR 86 Subpart 

A). The benefits of this program are reflected in the 2002 base year inventory and the 

2007 attainment year inventory. This federally implemented program affects light duty 

vehicles and light duty trucks. The regulations require more stringent exhaust emission 

standards as well as a uniform level of evaporative emission controls.

 National Low Emission Vehicle Program: Under the National Low Emission Vehicle 

program, automobile manufacturers agreed to comply with tailpipe standards that were

more stringent than USEPA could mandate prior to model year 2004 (40 CFR 86 Subpart 

R). Once manufacturers committed to the program, the standards became enforceable in 

the same manner in which other federal motor vehicle emission control requirements 

were enforceable. The program was in place nationwide for model year 2001, and the 

benefits of this program are reflected in the 2002 base year inventory and the 2007 

attainment year inventory.

 Tier 2 Motor Vehicle Emission Regulations: On February 10, 2000 (65 FR 6698), 

USEPA promulgated a rule requiring more stringent tailpipe emissions standards for all 

passenger vehicles, including sport utility vehicles, minivans, vans, and pick-up trucks. 

These regulations also required lower levels of sulfur in gasoline, which ensured the 

effectiveness of low emission control technologies in vehicles and reduced harmful air 

pollution. The tailpipe standards required passenger vehicles to be 77 to 95 percent

cleaner than those built before the rule was promulgated and the sulfur standards reduced 

the sulfur content of gasoline up to 90 percent by 2006. The benefits of this program are 

reflected in the 2007 attainment year on-road mobile inventory.

 

2 Details of onroad engine and fuel rules are available at - http://www.epa.gov/otaq/standards/index.htm
Washington, DC-MD-VA PM2.5 NAA Redesignation Request, May 22, 2013 11

 Heavy Duty Diesel Engine Rules: These federal rules required truck manufacturers to 

comply with more stringent tailpipe standards by 2004 (65 FR 59896, 10/6/2000) and 

2007 (66 FR 5002, 1/18/2001). The 2007 rule also mandated use of ultra-low sulfur 

diesel fuel to enable modern pollution control technology on trucks and buses. Refiners 

began producing the cleaner-burning diesel fuel for use in highway vehicles beginning 

June 1, 2006. The benefits of this program are reflected in the 2007 attainment year 

inventory for on-road mobile sources. 

 Enhanced Vehicle Inspection and Maintenance Programs: Enhanced vehicle emissions 

inspection and maintenance (enhanced I/M) requirements have been instituted by the 

District of Columbia (64 FR 31498, 06/11/1999), the State of Maryland (64 FR 58340, 

10/29/1999), and the Commonwealth of Virginia (64 FR 47670, 09/01/99). The 

requirements involve mandating regional vehicle emission I/M programs that are stricter 

than basic programs, as required under §§182 and 202 of the CAA. Before 1994, basic 

automobile emissions testing checked only tailpipe emissions while idling and sometimes 

at 2,500 rpm. Enhanced I/M procedures include the use of On Board Diagnostic (OBD) 

system evaluations, a wider range of vehicles tested, and may include a dynamometer 

(treadmill) test that checks the car’s emissions under driving conditions. The OBD 

evaluations provide a more complete inspection, checking for excess evaporative 

emissions and other issues that might affect emissions from the vehicle. The benefits of 

this program are reflected in the 2002 base year inventory and the 2007 attainment year 

inventory for on-road mobile sources.

The reductions in emissions from the on-road sector between 2002 and 2007 are

presented in Table 3-3. These emissions estimates are derived using the Motor Vehicle 

Emissions Simulator (MOVES2010a), Travel Demand Model Version 2.3, and the most recent 

planning assumptions as updated in the Metropolitan Washington Council of Governments 

Cooperative Forecast. To calculate incremental benefits from the implementation of the 

individual control measures listed above is very difficult. Therefore, the information presented 

summarizes the combined benefits of these rules. More information on the development of these 

emissions estimates may be found in the Technical Support Document (Appendix C1).

Table 3-3: On-Road Emission Reductions for the Washington DC-MD-VA Area, 2002-2007

2002 On-Road Emissions 2007 On-Road Emissions 2002-2007

% On-Road 

Reduction, 

Metro Wide

DC MD VA Metro 

Total DC MD VA Metro Total

SO2 On-Road Emissions, tpy

281 1,706 1,622 3,609 68 319 220 607 83%

NOX On-Road Emissions, tpy

9,963 63,392 53,598 126,953 7,512 47,279 36,848 91,639 28%

PM2.5 On-Road Emissions, tpy

302 2,057 1,600 3,959 272 1,757 1,422 3,452 13%
Washington, DC-MD-VA PM2.5 NAA Redesignation Request, May 22, 2013 12

3.2.2.2 Federal Consent Orders and Permitting Actions

Two federal settlements reduced emissions of NOX and SO2 significantly at electric 

generating units (EGUs) located within the Washington DC-MD-VA nonattainment area. In the 

first of these consent decrees, which was signed April 17, 2003, and involved Virginia Electric 

and Power Company (VEPCO), the Possum Point Power Station (ORIS33804) was required to 

switch two coal-fired boilers to natural gas (United States v. Virginia Electric and Power Co., 

Civil Action No. 03-CV-517A, entered 10/10/2003). Since the power station is located in 

Fairfax, Virginia, this consent decree resulted in significant reductions of emissions for both SO2

and NOX. Table 3-4 provides the percentage reduction of SO2 and NOX resulting from this 

consent decree.

Table 3-4: Possum Point Power Station Reductions, 2002-2007

Unit ID

2002 2007

Percent 

Reduction, 

SO2

Percent 

Reduction, 

NOX

SO2

Tpy

NOX

tpy

SO2

tpy

NOx

tpy

3 6,228 1,582 0 39 99+% 97.5%

4 10,975 2,349 1 111 99+% 95.3%

5 3,804 2,096 1,949 562 48.8% 73.2%

Total: 21,006 5,026 1,950 712 90.7% 63.5%

Data taken from USEPA’s CAMD database.

In a joint federal-state settlement, Mirant Mid-Atlantic agreed to eliminate nearly 29,000 

tons annually of harmful pollution generated by four plants located in the Washington DC-MDVA nonattainment area (United States and State of Maryland v. Mirant Mid-Atlantic, LLC and 

Mirant Potomac River, LLC, Civil Action No. 1:04CV1136). Under the terms of the settlement, 

Mirant capped NOX emissions on a system-wide basis from its Chalk Point Generating Plant

(ORIS 1571), in Prince George's County, Maryland; Dickerson Generating Plant (ORIS 1572), in 

Montgomery County, Maryland; Morgantown Generating Plant (ORIS 1573), in Charles County, 

Maryland; and Potomac River Generating Station (ORIS 3788), in Alexandria, Virginia. 

These consent decrees remain enforceable, and these facilities must continue to meet the 

pertinent applicable requirements. Tables 3-4 and 3-5 enumerate emission reductions achieved 

from these consent decrees by 2007. Additional reductions are required by each consent decree 

in future years so that regional air quality will continue to benefit from these decrees. These 

requirements will not change due to the redesignation of the Washington DC-MD-VA area to 

attainment.

 

3 EGUs are assigned a 4-digit ORIS (Office of the Regulatory Information System) identifier by the Energy 

Information Agency (EIA) of the US Department of Energy.
Washington, DC-MD-VA PM2.5 NAA Redesignation Request, May 22, 2013 13

Table 3-5: Washington DC-MD-VA Mirant System 2002-2007 NOX Reductions

Facility Unit 

ID

2002 NOX Emissions 2007 NOX Emissions % 

Reduction

lbs/mmbtu Tpy lbs/mmbtu tpy

Chalk Point 1 0.562 6,337 0.446 4,885 22.9%

Chalk Point 2 0.560 6,755 0.450 4,835 28.4%

Chalk Point 3 0.156 846 0.136 538 36.4%

Chalk Point 4 0.169 1,169 0.128 426 63.6%

Dickerson 1 0.466 2,121 0.343 1,645 22.5%

Dickerson 2 0.498 2,444 0.334 1,644 32.7%

Dickerson 3 0.471 2,661 0.338 1,658 37.7%

Morgantown 1 0.504 10,014 0.191 3,097 69%

Morgantown 2 0.501 8,605 0.360 6,321 26.5%

Potomac River 1 0.379 759 0.326 483 36.3%

Potomac River 2 0.416 789 0.287 444 43.7%

Potomac River 3 0.418 1,545 0.254 412 73.4%

Potomac River 4 0.415 1,443 0.234 481 66.6%

Potomac River 5 0.398 1,474 0.245 516 65.0%

Washington DC-MD-VA

Mirant System: 46,962 -- 27,386 42.7%

Source: USEPA’s CAMD database.

3.3 SIP Completeness

3.3.1 USEPA Requirements

States must provide assurances that the applicable implementation plan has been fully 

approved by USEPA under § 110(k) and must satisfy all requirements that apply to the area. 

Approval action on SIP elements and the redesignation request may occur simultaneously. An 

area cannot be redesignated if a required element of its plan is the subject of a disapproval; a 

finding of failure to submit or to implement the SIP; or partial, conditional, or limited approval. 

For purposes of redesignation, states must meet all requirements of § 110 and Part D of 

the CAA that were applicable prior to submittal of the complete redesignation request. Subpart 1 

of Part D consists of general requirements applicable to all areas that are designated 

nonattainment based on a violation of the NAAQS. Subpart 4 of Part D consists of more specific 

requirements applicable to particulate matter (specifically to address PM10). However, for the 

purpose of implementing the 1997 PM2.5 standard, the USEPA’s implementation rule stated 

Subpart 1, rather than Subpart 4, is appropriate (72 FR 20598, 4/25/2007).
Washington, DC-MD-VA PM2.5 NAA Redesignation Request, May 22, 2013 14

3.3.2 Washington DC-MD-VA Approach

The Washington DC-MD-VA area has had few SIP submittal requirements in the past 

since the area has not been a persistent nonattainment area for PM2.5. Since the area’s air quality 

improved so that the area met the 1997 PM2.5 NAAQS well prior to the 2010 compliance date, 

most requirements, other than those associated with major new source review permitting and 

conformity, were limited.

Section 110(a) of the CAA contains the general requirements for a SIP. As USEPA has 

stated in previous rulemaking4, only the § 110 and Part D requirements that are linked with a 

particular area’s designation are the relevant measures that should be considered in evaluating a 

redesignation request. The other § 110 elements that are not connected with nonattainment plan 

submissions and not linked with an area’s attainment status are also not applicable requirements 

for purposes of redesignation. A state remains subject to these requirements after an area is 

redesignated to attainment.

The requirements of § 110(a)(2) are statewide requirements that are not linked to the 

PM2.5 nonattainment status of the Washington, DC-MD-VA area. Therefore these SIP elements 

are not applicable requirements for purposes of review of the state’s PM2.5 redesignation request.

In accordance with the applicable PM2.5 implementation rule, USEPA’s determination 

that the Washington DC-MD-VA area attained the 1997 PM2.5 NAAQS (74 FR 1146) suspends 

a number of requirements contained in § 172(c) of the CAA so long as the area continues to 

attain the standard. These requirements include (1) attainment plan submission, (2) reasonably 

available control measures/reasonably available control technology determinations, (3) 

reasonable further progress determinations, and (4) contingency measures. Therefore, USEPA 

does not consider these mandates under § 172(c) to be SIP requirements for the purposes of 

redesignation. 

The requirement for a base year inventory under § 172(c)(3) of the CAA is not suspended 

by USEPA’s determination of attainment. The base year inventory for the Washington DC-MDVA area was contained in Chapter 3 and Appendix B of the Plan to Improve Air Quality in the 

Washington, DC-MD-VA Region. This documentation was submitted to USEPA in final form 

by the District of Columbia on April 2, 2008 (77 FR 61513); by the State of Maryland on March 

8, 2008 (77 FR 65630); and by the Commonwealth of Virginia on April 4, 2008 (77 FR 60626). 

The SIPs for the District of Columbia, the State of Maryland, and the Commonwealth of 

Virginia contain provisions that are consistent with the § 176(c)(4) conformity requirements. In 

the District of Columbia’s SIP, transportation and general conformity requirements are contained 

in 20 DCMR Chapter 15. In the State of Maryland’s SIP, both general conformity requirements

and transportation conformity requirements are contained in COMAR 26.11.26. In the 

Commonwealth of Virginia’s SIP, general conformity requirements are contained in 9VAC5 

 

4

See USEPA’s proposed approval of Ohio’s redesignation request for the Ohio portion of the Huntington-Ashland 

nonattainment area for the 1997 PM2.5 NAAQS. (76 FR 79593)
Washington, DC-MD-VA PM2.5 NAA Redesignation Request, May 22, 2013 15

Chapter 160 (Regulation for General Conformity) and transportation conformity requirements 

are contained in 9VAC5 Chapter 151 (Regulation for Transportation Conformity).

3.4 Maintenance Plan

3.4.1 USEPA Requirements

Section 107(d)(3)(E) of the CAA stipulates that for an area to be redesignated, USEPA 

must fully approve a maintenance plan that meets the requirements of § 175(A). States may 

submit both the redesignation request and the maintenance plan at the same time, and rulemaking 

on both may proceed on a parallel track. All applicable nonattainment area requirements remain 

in place. The maintenance plan will constitute a SIP revision and must provide for maintenance 

of the relevant NAAQS in the area for at least 10 years after redesignation. § 175(A) further 

states that the plan shall contain such additional measures, if any, as may be necessary to ensure 

such maintenance. States must also submit a SIP revision eight years after the original 

redesignation request is approved to provide for maintenance of the NAAQS for an additional 10 

years following the first 10-year period.

USEPA requires the following provisions to ensure maintenance of the NAAQS:

 The state must develop an attainment emissions inventory to identify the level of 

emissions in the area that is sufficient to attain the NAAQS.

 A state may generally demonstrate maintenance by showing that future emissions of a 

pollutant or its precursors will not exceed the level of the attainment inventory over the 

10-year period following redesignation.

 Once an area has been redesignated, the state must continue to operate an appropriate air 

quality monitoring network in order to verify the area's attainment status.

 The state must ensure that it has the legal authority to implement and enforce all 

measures necessary to attain and maintain the NAAQS. Continued attainment must be 

verified by the state by indicating how maintenance plan progress will be tracked.

 Contingency measures must be available to promptly correct any NAAQS violation. At a 

minimum, the contingency measures must include a requirement that the state will 

implement all measures contained in the nonattainment SIP prior to redesignation. 

3.4.2 Washington DC-MD-VA Approach

An appropriate maintenance plan for the area meeting all federal requirements is being 

submitted along with this redesignation request for each state in the Washington DC-MD-VA

area. This maintenance plan relies upon a variety of programs, which demonstrate that air 

quality will be maintained at least 10 years into the future. The plan contains contingency 

measures to be implemented in case of worsening air quality and mobile vehicle emission 

budgets for transportation conformity purposes.