SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST

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

SIP Submitted by: Maryland Department of Environment

 Date Submitted: November 15, 2012

Subject: Removal of Mount Saint Mary’s College 1979 Consent Order

Completeness Review 

Completed by: Maria Pino 

Date Completed: December 5, 2012

Administrative Materials ACCEPTABLE

EPA REQUIREMENT STATE SUBMITTAL (X)

1. A formal letter of submittal from the Governor or his 

designee, requesting EPA approval of the plan or revision 

thereof.

1. Yes, a letter dated November 15, 2012, from Robert M 

Summers, PhD, Secretary of the Maryland Department of the 

Environment

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. Yes, Maryland issued a permit to construct on July 18, 

2000 to remove the coal-firing capability and connect the boiler 

to natural gas with No. 2 fuel oil as backup.

3. Evidence that the State has the necessary legal authority 

under State law to adopt and implement the plan.

3. Yes, the permit to construct was issued in accordance with 

COMAR 26.11.02.04B on July 18, 2000.

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. Yes, a copy of the permit to construct, dated July 18, 2000 

was submitted. 
EPA REQUIREMENT STATE SUBMITTAL (X)

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. Yes, the submittal certifying that Maryland meets all the 

applicable requirements of 110(a)(2) was signed and submitted 

following the procedural requirements of the State.

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. Yes, notice of the public hearing was published in the 

Maryland Register on June 15, 2012 and on the Maryland 

Department of the Environment’s website from May 11, 2012 

to July 18, 2012.

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. Yes, a public hearing was held on July 18, 2012. No one 

attended the public hearing and no comments were received 

during the 30-day comment period.

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

thereto.

8. N/A

Technical Support

EPA REQUIREMENT STATE SUBMITTAL (X)

1. Identification of all regulated pollutants affected by the plan. 1. Yes, NOx, CO, and PM

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. Yes, the affected source is Mount Saint Mary’s University 

located in Emmitsburg, Maryland (Fredrick County).

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. Yes, expected emissions from the converted boiler are listed 

in parts per million, dry volume (PPMVD) and are as follows: 

NOx emissions-

-30 PPMVD or less (corrected to 3% O2) when 

firing natural gas only, 

-100 PPMVD or less (corrected to 3% O2) when 

firing No. 2 fuel oil when the nitrogen content of the 

fuel is <0.02% by weight; 

CO emissions-400 PPMVD or less (corrected to 3% O2)
EPA REQUIREMENT STATE SUBMITTAL (X)

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. Yes, the permit to construct was issued with conditions that 

limit NOx emissions from the source to less than 25 tons per 

year, based on a rolling 12-month average.

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 

the determination of adequacy of the modeling analysis.

5. N/A

6. Evidence, where necessary, that emission limitations are 

based on continuous emission reduction technology.

6. Yes, the permit to construct was issued and subject to all 

applicable State and Federal air pollution requirements, 

including COMAR 26.11.09.08F which specifies the 

requirements to implement Reasonable Available Control 

Technology (RACT) for the control of NOx emissions from 

“Space Heaters”.

7. Evidence that the plan contains emission limitations, work

practice standards and recordkeeping/reporting requirements, 

where necessary, to ensure emission levels.

7. Yes, the permit was issued with conditions that require the 

following: developing and implementing an operation and 

maintenance plan to minimize NOx emissions, in-State operator 

training once every 3 years, and prepare and maintain a record 

of training program attendance for each operator at the site.

8. Compliance/enforcement strategies, including how 

compliance will be determined in practice.

8. Yes, the permit was issued with conditions that include 

maintaining records of amounts and types of all fuels used and 

to make those records available to the Department as requested.

9. Special economic and technological justifications required 

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

explain why.)

9. N/A

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. N/A