UNITED STATES ENVIRONMENTAL PROTE C TION AGENCY REGION 6 1445 ROSS AVEN UE, SUITE 1200 DALLAS, TX 75202-2733



### Mr. Richard Goodyear Bureau Chie f, Air Quality Bureau New Mexico Env ironmental Department 525 Cami n o de los Marquez, Suite I Santa Fe, NM 87505 Dear Mr. Goodyear: On October 1 8 , 20 13, th e Environmental Protection Agency received r evis ions to the New Mex ico Regional H aze State Imp leme ntation Plan (S IP) includin g a rev i s i o n for the San Juan Generating Station (SJG S) Best Avai l ab l e Retrofit Technology D e termination . On November 5, 2013, we also received a tec hni cal modi fi cati o n to the New Source Review (NSR) permit fo r the SJGS s ubmitted as part of t he SIP p ackage , and re f ere n ced in the submittal letter dated October 7 , 20 1 3. We h ave re v iewed th e material s subm itted and have found that the y fu lfi ll t he co mpl e te n ess criteri a in 40 CFR Part 51 , Appendix V. In the coming months, we wi ll r ev iew th e complete revisions for action pursuant to C l ea n A ir Act sec ti on 11 O(k). If you have any que s ti o n s regarding the comp leteness rev iew o r the attac h e d c heck list , p l ease contact me at 2 14- 665-6583 , o r Mi chae l Feldman of my staff at 2 14- 665-9793. S inc ere l y ,
Wre n Stenger Director Mu l tim edia Pl annin g and

Permittin g Division

cc: Ms. Rita Bat es , Plannin g Section Chief, A ir Quality Bureau New Mex ic o En v iro nm ental Department Maure e n G annon , Execu ti ve Director, Enviro nmen ta l Serv ices

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### SIP Submitted by: Dat e Received: 

### SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST (In accordance with 40 CFR Part 51
- App. V) 

### New Mexico Environmental Department (NMED) October 18, 

### 2013 Subject: 

### Revision to the State Implementation Plan for the San Juan Generating Station Best Available Retrofit Technology Determination Docket: EPA -R06
- 0AR
- 2010-0846 Completeness Review Completed by: Michael Feldman December 13 , 20 13 Staff Review Date Completed: 

### Administrative Materials Item EPA Requirement



### 1 The package is sent with a fonnal submittal letter from the Governor or his or her design ee requesting EPA's approval of the revision. Evidence is included that the State has adopted the rev i sion in the State code or body of regulations, or that the State has issued the 

### 2 penni t , order, consent ag ree ment (hereafter document) in final fonn. This evidence would include effective date of rev i sio n , if different from adoption/issuance date. Evide nce is includ ed that the State has necessary legal authority 

### 3 under State law to adopt and implemen t the revi s ion, e.g., a cita t ion of the app ropriate State authority. State Submittal The SIP package was submitted with a formal letter signed by Ryan Flynn, Cabinet Secretary-Designate.

Date of ado ption by the New Mexico Environme ntal improvement Board: September 5 , 2013

Th e SIP package contains "Order and Stateme nt of Rea so n s for Adoption of SIP Revi s ions " which identifies th e authority to adopt the propo sed SJP revisions pursuant to N.M.S.A.l978, §§ 74-2-5.8 & C. Page I Acceptable? y N 

### X

X

XAcceptable? Item EPA Requirement State Submittal y N A copy is includ ed of the actual regulation o r document submitted f o r ap prova l and in corporatio n by reference into the S IP includin g an indication of the changes made t o the exi sting approved plan 

### 4 where applicabl e. The submittal shall be a copy of the official State The SIP package contains all revisions t o the Regional 

### X regulation document signed , stamped, and dated by the appropriate Haze SIP and s upporting appendices. State official indicating that i t i s fully enforceab le by the State. The e ff ective date o f the regulation document s hall, whenever p ossib le , be indicated in th e d oc um ent its elf. Evidence is included that the State followed all the procedural The S IP package outlines applicab le pu blic participati on requirements of its laws and/o r its constitution in the conducting and 

### 5 completing the adoption/ issuance of the plan. This evidence may be: procedures in " Notice of Pu b li cation of Hea r ing Notice and 

### X a checklist of required steps ; a copy of the requirements wi th each Public Revi ew Drafts " with which all supporting step clearly identified ; or other appropriate documentation. documentation i s consistent.
Ev id enc e is included that public notice was give n of the proposed Copies of the public notice and affidavits o f publication changes consi sten t with the procedures approve d by the EPA , were included as Exhibit 7 of the SIP package. Proof of 

### 6 including the date of publication of such notice, (e.g., notarized or publications , proof of oppo1tunity for public hearing , and 

### X certified copies of any publi c notices publi s hed in new spapers). (The transcript of public hearin g were included as component s noti c e s hould b e a t least 30 da ys prior to the public hearing (s ) . o f the SIP submittal. A certification is included indi cati ng that public hearin g(s) was/were A transcript of the public hearin g is provided and the 

### 7 held in accordan ce with the inf o nnation provided in the public " Order and s tate ment of Rea son s for Adoptio n of SIP 

### X not ice(s) and the State's law s and constitution, if applicable. Revisions " states that a hearing was held o n September 5 th . A compilation of public comments and the State's respon se is The SIP submittal package co ntains publi c comments, a 

### 8 in c luded. transcript of the public hearin g , and technical testimony , as 

### X well as re s po n ses to comments .

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### Technical Materials Acceptable? Item E PA Requirement State Submittal y N

1 Identification of all regulated pollutants affected by the rev i sion is The po ll uta n ts of concern are NOx, S02 a nd PM 

### X included . Identification of the locations of affected sources including the EPA T echnical support is based on visib ili ty. However, the 

### 2 attainment/nonattainment designation of the locations and the status location of the affected source is current l y 

### X of the attainment plan for the affected area(s) is inc l uded. attainment/unclassified for all criteria pollutants. Quantificati o n of the changes in SIP allowab le emissions from the affected s ources is included. (Examples include estimates of changes in current actual emissions from affected sources and/or, where SIP package contains appropriately quanti fied emission 

### 3 appropriate, quantification of changes in actual emissions from 

### X affected sources through calculations of the differences betw een limitations for NOx , S02 and PM . certain baseline levels and allowable emissions anticipated if the revisions were approved.) Demonstration is included that the NAAQS/ PSD increments/RFP The SIP package contains necessary demonstration that 

### 4 demonstration and visibility, as applicable, would be protected if the 

### X revision were approved and implemented . visibility will be protected . Is there a fully approved maintenance plan for the primary ambient 

### 5 air quality standards for at least 10 years as requ ired by 

### § 175A of The SIP revision is not a maintenance p lan . 

### X th e C l ean Air Act? 

### 6 Are contingency measures included? Not for th i s SIP revision . 

### X

- ----- Pag e 3i Acc e ptable? I Item E PA Requirement Sta te Submittal y N Modeling inf onnatio n required to su pport the proposed revision, including inpu t data , o utput data, mo de l s used , ju s tifi catio n of 

### 7 model( s) se lected , ambient mon itori ng data used, meteorological Modeling in formation was provided to support the EPA 

### X data used , jus ti fication for u se of off si te data (whe re used), mode s of r eview. models u se d, assum p tions , and other infonnation relevant t o the determination o f ad eq ua cy of the modeling analysis as needed . Evidence is includ ed , where necessary, that emission l imitation s a re 

### 8 based on continuou s e mi ss ion reduc t ion technology (e.g. , add-on Emi ss io n limitations are based on the CAA requiremen t for 

### X controls , industrial/process eq uipment designs , refonnu lated BART. materials, etc.) . Evidence i s in cluded indi catin g that a SIP revis ion contains the Emi ss ion l imitati o ns and applicable a ve ra ging 

### 9 following to e n s ure stated emission levels: e mission limitations , methodo logy a r e prov ided wi th the S IP package in t he SIP 

### X narrative and in the tech ni cal modification to the 

### NS R work practice standard s , and reco rdkeepinglreporting re quirements. permit sub m itted as part of the SIP package . 

### 10 Compliance / enfo r cement s trateg ie s in clud ing how compl iance will Th e S IP rev i sion builds o n the state's exi sti ng methods for 

### X b e detenn in ed in practi ce ( including at what frequency). determining comp li ance. Evidence is includ e d as ap prop riate , special economic and technological ju s tifi ca ti o n s are included per app licable EPA p o licies 

### 11 or an exp lanat ion wh y s uch ju sti fications are not nece ssary s h ou ld Not app li cab le. 

### X be included. For examp le, the fo ll o wing types of request may re q uire such ju stifica ti on: Alte rnative RACT, Long-term averaging YOC emission l imit s , Plant wide Averaging.



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Page 4Co nclusion: 

### X The pro pos ed SIP actio n meet s the compl ete ness cri te ria.



## - -- The propo se d S IP action does N OT meet the complet e ness criteria.

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