UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION 6 

1445 ROSS AVENUE, SUITE 1200 

DALLAS, TX 75202-2733 

Mr. Richard Goodyear 

Bureau Chief, Air Quality Bureau 

New Mexico Environmental Department 

525 Camino de los Marquez, Suite I 

Santa Fe, NM 87505 

Dear Mr. Goodyear: 

On October 18, 20 13, the Environmental Protection Agency received revisions to the New Mexico 

Regional Haze State Implementation Plan (SIP) including a revision for the San Juan Generating Station 

(SJGS) Best Available Retrofit Technology Determination. On November 5, 2013, we also received a 

technical modifi cation to the New Source Review (NSR) permit for the SJGS submitted as part of the 

SIP package, and referenced in the submittal letter dated October 7, 20 13. We have reviewed the 

materials submitted and have found that they fulfill the completeness criteria in 40 CFR Part 51 , 

Appendix V. In the coming months, we will review the complete revisions for action pursuant to Clean 

Air Act section 11 O(k). 

If you have any questions regarding the completeness review or the attached checklist, please contact me 

at 214-665-6583, or Michael Feldman of my staff at 214-665-9793. 

Sincerely, 

Wren Stenger 

Director 

Multimedia Planning and 

Permitting Division 

cc: Ms. Rita Bates, Planning Section Chief, Air Quality Bureau 

New Mexico Environmental Department 

Maureen Gannon, Executive Director, 

Environmental Services 

RecycledJRecycl•bl• • Printed With Vegetable 011 Based Inks on 100% Recycled Paper (40% Postconsumer) 
SIP Submitted by: 

Date 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 

Staff Review Date Completed: December 13, 20 13 

Administrative Materials 

Item EPA Requirement 

1 The package is sent with a fonnal submittal letter from the Governor 

or his or her designee requesting EPA's approval of the revision. 

Evidence is included that the State has adopted the revision in the 

State code or body of regulations, or that the State has issued the 

2 pennit, order, consent agreement (hereafter document) in final fonn. 

This evidence would include effective date of revision, if different 

from adoption/issuance date. 

Evidence is included that the State has necessary legal authority 

3 under State law to adopt and implement the revision, e.g., a citation 

of the appropriate State authority. 

State Submittal 

The SIP package was submitted with a formal letter signed 

by Ryan Flynn, Cabinet Secretary-Designate. 

Date of adoption by the New Mexico Environmental 

improvement Board: September 5, 2013 

The SIP package contains "Order and Statement of 

Reasons for Adoption of SIP Revisions" which identifies 

the authority to adopt the proposed SJP revisions pursuant 

to N.M.S.A.l978, §§ 74-2-5.8 & C. 

Page I 

Acceptable? 

y N 

X 

X 

X 
Acceptable? 

Item EPA Requirement State Submittal 

y N 

A copy is included of the actual regulation or document submitted 

for approval and incorporation by reference into the SIP including 

an indication of the changes made to the existing approved plan 

4 where applicable. The submittal shall be a copy of the official State The SIP package contains all revisions to the Regional X regulation document signed, stamped, and dated by the appropriate Haze SIP and supporting appendices. 

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. 

Evidence is included that the State followed all the procedural The SIP package outlines applicable public participation requirements of its laws and/or its constitution in the conducting and 

5 completing the adoption/issuance of the plan. This evidence may be: procedures in "Notice of Publication of Hearing Notice and X 

a checklist of required steps; a copy of the requirements with each Public Review Drafts" with which all supporting 

step clearly identified; or other appropriate documentation. documentation is consistent. 

Evidence is included that public notice was given of the proposed Copies of the public notice and affidavits of publication 

changes consistent with the procedures approved 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 public notices published in newspapers). (The transcript of public hearing were included as components 

notice should be at least 30 days prior to the public hearing(s). of the SIP submittal. 

A certification is included indicating that public hearing(s) was/were A transcript of the public hearing is provided and the 

7 held in accordance with the infonnation provided in the public "Order and statement of Reasons for Adoption of SIP X 

notice(s) and the State's laws and constitution, if applicable. Revisions" states that a hearing was held on September 5th. 

A compilation of public comments and the State's response is The SIP submittal package contains public comments, a 

8 included. transcript of the public hearing, and technical testimony, as X 

well as responses to comments. 

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Technical Materials 

Acceptable? 

Item EPA Requirement State Submittal 

y N 

1 

Identification of all regulated pollutants affected by the revision is The pollutants of concern are NOx, S02 and PM X included. 

Identification of the locations of affected sources including the EPA Technical support is based on visibility. However, the 

2 attainment/nonattainment designation of the locations and the status location of the affected source is currently X 

of the attainment plan for the affected area(s) is included. attainment/unclassified for all criteria pollutants. 

Quantification of the changes in SIP allowable emissions from the 

affected sources is included. (Examples include estimates of changes 

in current actual emissions from affected sources and/or, where SIP package contains appropriately quantified emission 3 appropriate, quantification of changes in actual emissions from X 

affected sources through calculations of the differences between 

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 required by § 175A of The SIP revision is not a maintenance plan. X 

the Clean Air Act? 

6 Are contingency measures included? Not for this SIP revision. X 

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i 

Acceptable? I 

Item EPA Requirement State Submittal 

y N 

Modeling infonnation required to support the proposed revision, 

including input data, output data, models used, justification of 

7 model(s) selected, ambient monitoring data used, meteorological Modeling information was provided to support the EPA X data used, justification for use of offsite data (where used), modes of review. 

models used, assumptions, and other infonnation relevant to the 

determination of adequacy of the modeling analysis as needed. 

Evidence is included, where necessary, that emission limitations are 

8 based on continuous emission reduction technology (e.g., add-on Emission limitations are based on the CAA requirement for X controls, industrial/process equipment designs, refonnu lated BART. 

materials, etc.). 

Evidence is included indicating that a SIP revision contains the Emission limitations and applicable averaging 

9 following to ensure stated emission levels: emission limitations, methodology are provided with the SIP package in the SIP X 

narrative and in the technical modification to the NSR work practice standards, and recordkeepinglreporting requirements. permit submitted as part of the SIP package. 

10 Compliance/enforcement strategies including how compliance will The SIP revision builds on the state's existing methods for X be detennined in practice (including at what frequency). determining compliance. 

Evidence is included as appropriate, special economic and 

technological justifications are included per applicable EPA policies 

11 or an explanation why such justifications are not necessary should Not applicable. X 

be included. For example, the following types of request may 

require such justification: Alternative RACT, Long-term averaging 

YOC emission limits, Plant wide Averaging. 

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Page 4 
Conclusion: X The proposed SIP action meets the completeness criteria. 

- -- The proposed SIP action does NOT meet the completeness criteria. 

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