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 enforcea ble 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

fo llowing 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, NO

x , 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

locat ed 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 change s 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:

N O

x emissions

-

- 30 PPMVD or less (corrected to 3% O 2 ) when firing natural gas only,

- 100 PPMVD or less (corrected to 3% O 2 ) 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% O 2 )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 implemente d. 4. Yes, the permit to construct was issued with conditions that

limit NO

x 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 mod eling 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 NO

x 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 implement ing an operation and maintenance plan to minimize NO

x 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