# MDE MARYLAND DEPARTMENT OF THE ENVIRONMENT 1800 Washington Boulevard. Baltimore MD 21230 410-537-3000. 1-800-633-6101 Martin O'Malley Governor Anthony G. Brown Lieutenant Governor 

# APR S .. 2.008
Mr. Donald Welsh Regional Administrator (3RAOO) U.S. Environmental Protection Agency Region 

## III 1650 Arch Street Philadelphia, PA 19102-2023 Dear Mr. Welsh: Shari T. Wilson Secretary Robert M. Summers, Ph.D. Deputy Secretary



## The purpose ofthis letter is to submit copies ofMaryland's Fine Particle (PM2s) State Implementation Plan (SIP #08-06) and 2002 Base Year Inventory for the Metropolitan Washington, DC-MD-VA Nonattainment area. This SIP submission consists ofa reasonable further progress plan, an attainment demonstration, a reasonable available control measure analysis, contingency plans and mobile source emission budgets. The plan also contains the base year 2002 PM2 .5 

## emissions inventory and 2009 projected inventory, which serves as the basis for all planning activities related to the 1997 PM2.5 National Ambient Air Quality Standard for the Washington DC-MD-VANonattainment Area. A public hearing for this submission was held in Maryland at the Maryland-National Capitol Park and Planning Commission (M-NCPPC) in Silver Spring, Maryland onJanuary 30, 2008. All required administrative procedures were followed throughout the hearing process. Ifyou have any questions concerningthis submission, please feel free to call George (Tad) Aburn, Jr., Director ofthe Air and Radiation Management Administration at (410) 537-3255. 

## Sincerely, 

# I 

# JL**~ilson** Secretary Enclosures

cc: Judy Katz, USEPA Region III George (Tad) Aburn, Jr., Director, ARMA, MDE**~** Recycled Paper 

### www.mde.state.md.us TTY Users 

## 1-800-735-2258 ViaMaryland Relay Service

# MARYLAND DEPARTMENT OF THE ENVIRONMENT 1800 Washington Boulevard. Baltimore MD 21230 

# MDE 410-537-3000. 1-800-633-6101

Martin O'Malley Shari T. Wilson Governor Secretary Anthony Brown Robert \1. Summers, Ph.D. Lt. Governor Deputy Secretary 

# MarylandStateImplementation Plan (PM 2.

# s

# SIP) StateImplementation Plan for FineParticle (PM 2.S ) 

# Standardand2002Base YearInventory for the Washington DC-MD- VA NonattainmentArea SIPNumber: 08-06 April 5, 2008 Submitted to: u.S. Environmental Protection Agency Region 3 Air Protection Division 1650 Arch Street

Philadelphia, Pennsylvania 17108-1086 Prepared by: Maryland Department ofthe Environment



# MDE

## MWAQC D.C.DOE:

Virginia:

Maryland: Public Hearing Dates and Locations For the Draft 

## PM2• 5

## SIP Virginia January 

## 29,2008, 7 pm George Mason High School 

## 7124 Leesburg Pike, Falls Church, VA Maryland January 

## 30,20086pm MNCPPC 18t 

## FloorAuditorium 

## 8787 GeorgiaAvenue, Silver Spring, 

## MD District ofColumbia February 11, 

## 2008 6 pm DistrictDepartment ofthe Environment 

## 51 N Street, NW, 

## 6th 

## floor, Washington, DC

PUBLIC COMMENT DEADLINES AND ADDRESSES Email: mwaqcpubliccomment@mwcog.org CecilyBeall DistrictDept. ofthe Environment Air QualityDivision 

## 51 N St., NE, Washington, D.C. 

## 20002 cecily.beall@dc.gov Doris McLeod Virginia Dept. of Environmental Quality P.O. Box 1105 Richmond, VA 

## 23218 damc1eod@deq.virginia.gov Brian J. Hug Air QualityPlanning Program Maryland Department ofthe Environment 

## 1800 Washington Boulevard Baltimore, Maryland 

## 21237 bhug@mde.state.md.us

# Maryland Department ofthe Environment Notice ofPublic Hearing on Air Quality Plan

The Maryland Department ofthe Environment (MDE) will hold a Public Hearing on a State Implementation Plan (SIP) addressing the Annual Fine Particle (PM 2.5) 

## Standard for the Washington DCMD-VANonattainmentArea. The Washington DC-MD-VA Nonattainment Areaincludes the following Maryland counties: Charles, Frederick, Montgomery, and Prince George's. The Hearing will be held on: January 30, 2008 at 6:00 PM at the Maryland National Capitol Park and Planning Commission, First Floor Auditorium, 8787 Georgia Avenue, Silver Spring, Maryland. The Public Hearing will be held as required by federal law (Clean Air Act at 42 U.S.C. 7410 (a) and 40 CFR 51.102). The proposed plan is titled the State Implementation Plan (SIP)forAnnualFine Particle (PM 2.5) 

## Standard and2002 Base Year Inventory for the Washington DC-MD-VA NonattainmentArea. 

## The plan contains emission inventories, control measures, an attainment demonstration and motor vehicle emission budgets. This plan contains the base year 2002 airpollutant emissions inventory and 2009 projected inventory, which serves as the basis for all planning activities related to the Annual Fine Particle Standard for the Washington DC-MD-VA Nonattainment Area. On December 12,2007,the Metropolitan Washington Air Quality Committee (MWAQC) approved the proposed plan for release for public review and comment. After consideration ofcomments received, the plan will be finalized and submittedto the United State Environmental·ProtectionAgency. The SIP document has been made available onthe Maryland Department ofthe Environment's website at http://www.mde.state.md.us/Programs/AirPrograms/air planning/index.asp titled the "Planto Improve Air Quality in the Washington, DC-MD-VA Region" Note: the public library systems in the region can be used for Internet access to viewthe document. Copies ofthe document canbe viewed atthe following locations: 1. 

## Maryland Department ofthe Environment Office, Air and Radiation Management Administration, 1800 Washington Boulevard, Suite 730, Baltimore, Maryland

- Contact: Randall Carroll or Brian Hug. 2. Metropolitan Washington Council ofGovernments, Suite 300, 777 North Capitol Street, NE, Washington, DC 20002

- Contact: Jeffrey King

## Comments may be presented at the hearing, mailed, emailed, or faxed to Brian

## J. Hug, Maryland Department ofthe Environment, Air and Radiation Management Administration, 1800 Washington Boulevard, Baltimore, MD, 21230, Fax# 410-537-4223, bhug@mde.state.md.us to be received before close ofbusiness January 30, 2008. A hearing impairedpersonmayrequest that an interpreter be present atthe hearing by notifying MDE five (5) business days before the hearing. TTY viaMaryland Relay for the hearing impaired is (410) 537- 4396. For more information contact Randall Carroll, Air QualityPlanner, at (410) 537-3252 (Toll free in Maryland call (800) 633-6101 ext. 3252) or RCarroll@mde.state.md.us.

# (
PROOF OFPUBLICATION I, Michael E. Phelps, Publisher ofThe WashingtonExaminer, (Maryland Edition) a newspaper inthe area of Maryland, published in the English language and located intheMaryland area, and entered in anewspaperof record according to the Laws and Regulations ofthe United States of America for 52 

## successive Weeks or more priorto the 

## issue ofDecember 27, 2007, 

## certifythat the notice of: Air Quality Plan 

## for Maryland Department of EnvironmentFiscal Services Division. Attached hereto has

## been publishedon December 27, 2007.



## Michael E. Phelps

27

# u. ofDecember 2007 

# a ·ati?£

Ad Number: 624135 End Date: December 27. 2007 Run Date: December 27,2007 Air Quality Plan 

## Maryland Department of

## Environment Fiscal Services Division 

# \MarylandDepartm

.. Notice

### ofPubUcHearl 

### TheMarylandDepartmentofthe

### Environment (MOE) ""

. Plan (Sun 

### addressingthe

### AnnualFineParticle (PM 2.5) S



### mentArea. 

### TheWasliingtonDC-MD·VANonattainment Charles, 

### Frederick. Montgomery. and

### Prince**Geor~s.**

## n**Jan~30,2008**

### at

# _PM atthe**~and**

### NationalC 

### dltorlam,8787GeoJ'lllaAvenue.SIhirSpring.

### Maryl 

### ThePublicHearingwillbe

### held 

### asrequired by

### federalla

.. 51.102). 

### TheproposedI'lanIstided

### theStar,lmplementaNon PIa 

### 2002Base Yearlnuenrory for

### rhBWashington 

### OC-MD-VA j 

### ventories,**~**

### measures, 

### anattaburientdemonstrat!. taInsthebaseyear2002 air

### pollutant

### emissionsinventor basis

### for

# an**p~**

### aaivitlesrelated

### totheAnnual Firu 

### NonattaJnm:ent

### Area. On

### December 12,

### 2007. the

### MetropolitanWasbJngtonAb 

### planforreleaseforpubUcreviewand

### comment After

### co ilalizedand submittedtotheUnited State

### Environmenta The

### SIPdocument

### baabeenmadeavailableonthe

### Maryi

# ~**·"=':~L::Yfb.~~=!!9=&~ ~**  temet

### accesstoview document. 1; 

### Copiesoftbe

# document~,~beviewedatthefolJowing 

### Ie l;

. 

### I. M!U}'land

### Dep ent

### oftheEnvironmentOOl(**~** 

### Adniinistradon, 800Washington

### Boulevard. Su

, RandallCarroD orBrianHug. 2. MetropolitanWashingtonCouncilofGovemme WashJhgton, DC200(12 •

### Contact:JeffreyKing



## DO**~-lOr** 

## DISG,\RD

Rct.Jin For Your Reccrds



### 10 15 15th

## Street NV'{, 

## Suite 500,Washington,

## DC " 20005 k 

### Main: 202-903-2000 ./( Fax: 202·903·2004 6850

## Versal CenterDrive. Suite 300,

## Springfield.Virginia**~** 

### 22151 • Main: 103-839-8320**.~** 

### Fax: 103-138-0619 

## 'Yvww.dcexaminer.com

# ---!~------------------------------------------------~
MarylandDepartmentoftheEnvironment NoticeofPublicHearingonAIr'

### Quality

### Plan TheMarylandDepartmentoftheEnvironment (MDE) willholda PublicHearingona StateImplementation Plan (SIP) addressingtheAnnualFineParticle (PM 2.5) StandardfortheWashingtonDC-MD-VANonattainmentArea. TheWashingtonDC-MD-VANonattainmentAreaincludesthefollowingMarylandcounties: Charles,Frederick. Montgomery,andPrinceGeorge's.TheHearingwillbeheldon: January30,2008at

### ti:ODPM

### attheMarylandNationalcapitolParkandPlanningCommIssion,FirstFloor Auditorium,8787GeorgiaAvenue,SilverSpring,Maryland. ThePublicHearingwillbeheldasrequiredbyfederallaw(CleanAirActat42 U.S.C. 7410 (a) and40 CFR 51.102). Theproposedplanis titledtheStateImplementationPlan (SIP) for AnnualFineParticle (PM2.5)Standardand 2002Base YearInventory fortheWashingtonDC-MD- VANonattainmentArea. Theplancontainsemissioninventories, controlmeasures, anattainmentdemonstrationandmotorvehicle emissionbudgets. Thisplancon- tainsthebaseyear2002 airl?ollutantemissionsinventoryand2009projectedinventory.whichservesasthe basisfor allplarmingactivitiesrelatedtotheAnnualFineParticleStandardfor theWashingtonDC-MD-VA NonattainmentArea. OnDecember 12,2007,theMetropolitanWashingtonAirQualityCommittee(MWAQC) approvedtheproposed 'llanforrelease for publicreviewandcomment. Afterconsiderationofcommentsreceived, theplanwill befilalizedandsubmittedtotheUnitedStateEnvironmentalProtectionAgency. TheSIPdocumenthasbeenmadeavailableontheMarylandDepartmentoftheEnvironment'swebsiteat http;/**/www.mde.state.md.us/Pro~s/AirPr~s/air** planning/index,asptitledthe"Planto ImproveAir QUalityintheWashington. DC-M -VARegion" ote:thepubliclibrarysystemsintheregion canbeusedfor Internetaccesstoviewthedocument. Copiesofthedocumentcanbeviewedatthefollowinglocations; 1. MarylandDepartmentoftheEnvironmentOffice.AirandRadiationManagement Administration, 1800WashingtonBoulevard, Suite730, Baltimore,Maryland

-Contact: Randall CarrollorBrianHug. 2. MetropolitanWashingtonCouncilofGovernments,Suite300, 777 NorthCapitolStreet. NE. Washington,DC20002

- Contact:JeffreyKing Commentsmaybepresentedatthehearing, mailed.emailed.orfaxedtoBrian

### J. Hug. MarylandDepartmentof theEnvironment,AirandRadiationManagementAdministration, 1800WashingtonBoulevard. Baltimore.MD. 21230,Fax#410·537-4223, bhug@mde.state.md.usto bereceivedbeforecloseoJbusinessJanuary30,2008. AhearingimpairedpersonmayrequestthataninterpreterbepresentatthehearingbynotifyingMDEfive (5) businessdaysbeforethehearing. TIYviaMarylandRelayforthehearingimpairedis (410) 537-4396. FormoreinformationcontactRandallCarroll,AirQualityPlarmer. at(410) 537-3252 (Tollfree inMarylandcall (800) 633-6101 ext. 3252) orRCarroll@mde.state.md.us.

. December27. 2007 624135**~~--------------------------------------------4-**Ad # 10248590 Name MD DEPT ENVIRON AIR 

### & RADIATION MGT ATTN Size 144 Lines TOaO Class 820 PO#**Autho~ized** by Account 10100460

PROOF OF PUBLICATION**Dist~ict** of Columbia, ss., Personally appeared**befo~e** me, a**Nota~y** Public in and**fo~** the said District, Nicole McKinney well known to me to be Bil**Manage~** of The Washington Post, a daily**newspape~** published in the of**Dist~ict** of Colurrbia, and oath in due**fo~m** of law that an advertisement containing the language annexed hereto was published in said newspaper on the dates mentioned in the certificate herein. I Hereby Certify that the attached advertisement was published in The Washington Post, a daily newspaper, upon the following date(s) at a cost of $1,084.24 and was circulated in the Washington metropblitan area. ?ublished 2 time(s). Account 1010046059

Witness my hand

My commission expires

Maryland Department of the Environment Notice of Public Hearing on Air Quality Plan The Maryland Department of the Environment (MOE) will hold a Public Hearing on a State Implementation Plan

# 20~

.'011

:312; addressing the**Ann~al** Fine Particle (PM 2.5) Standard for the Washington DC-MD-VA Nonattainment Area. The Washington DC-MD-VA Nonattainment Area includes the fol:owing Maryland counties: Char:es,**Frede~ick, Mcntgome~y,**  and Prince

# ~ The Washington Post washingtonpost.com ! rge's. The Hearing will be held on: January 30, 2008 at 6:00 PM at the Maryland National**Cap~tol** Park and Planning**Corrmiss~on,** E"irst Floor Auaitorium, 

### >:3787 Georqia Avenue, Spring, Maryland. The Puolic Hearing 1**b~** neld as required 

# Washington 

# PostMedia express EI Tiempo latino I 

### Shan'nel McCanneli Slate Account Executive BUSiness and Flanancial Opportunities

# ;~o~~~~~~;OSfta

### 1 00

1l5

6 0 215fh Streel NW 

### I Washington, 

## ex: 20071 b .'

. 71150exl457a71 f 202334.6724 e uSlnessopps@Washpost.comAd # 10248590 

### Class 820 POif Name MD DEPT ENVIRON AIR 

### & RADIATION MGT ATTN 

### Authorized 

### by by federal law (Clean Alr Act at 42 U.S.C. 7410 (a) and 40 CFR 51.102). The proposed plan is titled the State Implementation Plan :S:P) for Annual Fine Particle (PM 2.5) Standard and 2002 Base Year Inventory for the Washington DC-MD-VA Nonattainment Area. The plan contains emission lnventories, control measures, an attainment demonstration and motor vehicle emission budgets. This plan contains the base year 2002 air pollutant emissions inventory and 2009 projected inventory, which serves as the basis for all planning activities related to the Annual Fine Particle Standard for the Washington DC-MDVA Nonattainment Area. On December 12, 2007, the Metropolitan Washington Air Quality**Co~mittee** (MWAQC) approved t:he proposed plan for release for public review and C:OlTc8ent. After consideration of com."'.ent s recei ved, the plan will be finalized and Submitted to the United State Environmental Protection Agency. The SIP document has been made avallable on the Maryland Department of [he Environment's website at http:// www.mde. state.md.us/ Programs/AirPrograms/**ir~plannlng/index.asp** titled the #Plan to :mprcve Air**Q~al~ty** in thp Washingtcn, DC-MD-VA Size 144 Lines T0002 Account 1010046059Ad # 10248590 Name MD DEPT ENVIRON AIR & RADIATION MGT ATTN Class 820 PO# Authorized by

Region" Note: the public library systems in the region can be used for Internet access to view the document. Copies of the document can be viewed at the following locations: 1. Maryland Department of the Environment Office, Air and Radiation Management Administration, 1800 Washington Boulevard, Suite 730, Baltimore, Maryland # Contact: Randall Carroll or Brian Hug. 2. Metropolitan Washington Council of Governments, Suite 300, 777 North Capitol Street, NE, Washington, DC 20002 • Contact: Jeffrey King.**Co~ments** may be presented at the hearing, mailed, emailed, or faxed to Brian J. Hug, Maryland Department of the Environment, Air and Radiation Management Administration, 1800 Washington Boulevard, Baltimore, MD, 21230, Fax' 410-537 4223, bhug@mde.state.md.us to be received before close of business January 30, 2008. A hearing impaired person may request that an interpreter be present at**t~e** hearing by notifying MOE five (5) business days before the**near~ng.** 

### TTY via**~d~jland** Relay for :he**~earln1** impalred**~s ,~**  •• 537-4396. For re information contact ?andall 

### Carroll. Air Qua ity Planner, at :41) 37-3252 (Tal**fr~e** n Maryland call Size 144 Lines T0003 Account 1010046059Ad # 10248590 Class 820 POlt 

### Name MD DEPT ENVIRON AIR & 

### RADIATION MGT ATTN 

## Authorized by
(800) 633-6101 ext. 3252) or RCarroll@mde.state.md.us

.'**~.** 

### Size 144 Lines T0004 

## Account 1010046059

## MWCOG.org

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Enviror"lf1'\iElJit Housing .& 

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### Events Calendar Committee Bi.!$lness Ne1

### Ns Room Pre 

### MWAQC Releases New Air Quality Plan for Comment 

## co The Metropolitan WasHington Air Quality Committee (MWAQC) has approved for comment an air quality plan to reduce fine particle pollution in the region. Fine particle Issl 

### pollution is a mixture ofmicroscopic solids and liquid droplets suspended in air. At 2.5 microns in diameter, the small particles can get deep into lungs and even the COl 

### bloodstream. People with heart or lung disease, older adults and children are at

.. greater risk from this type of pollution. Levels offine particle pollution have been declining in the region since 2005, and under the regional plan released for public comment, these levels are expected to continue to decrease. While levels offine particles in the region are actually meeting the current U.S. Environmental Protection Agency (EPA) national standard, MWAQC decided to issue a more stringent plan than required because several states, including Maryland and the District ofColumbia, have challenged EPA on the standard, arguing that it 

## IS not protective enough of public health. In 1997, EPA set an annual fine particle standard less stringent than the Clean Air Scientific Advisory Committee, an independent EPA advisory body, recommended. "Even though the region has complied with EPA's annual fine particle standard, MWAQC has prepared a plan to further reduce levels offine particle pollution by 2009,» said MWAQC Chair and Montgomery County Council Member Nancy Floreen. "Through wind purchases and green buildings, improving energy efficiency, and increasing tree canopy in the region, local governments are helping reduce fine particle pollution even further: Measures included in the region's ozone plan released earlier this year will also reduce levels offine particles in next three years. States in the region are adopting the Clean Air Interstate Rule (in Maryland, the "Healthy Air Act") that will reduce pollution from power plants. The state rules will reduce sulfur dioxide, a major component of fine particles, from power plants by 80% starting in 2010. Cleaner car and truck engine technology and low sulfur fuel will also reduce fine particles. The states will announce the beginning ofthe**3~-day** 

### public comment period around December 28, and it will end with public hearings in the region the week ofJanuary 28, 2008. The plan will be available on the COG website at: http://sharepointmwcog.org/airquality/Shared%20DocumentslForms/Allltems.aspx For further information see**~.mwcog.Qrgl~n\li[onm~!1V~jr**



### Release Date: Dec 14, 2007 Contact: Steven Kania Phone: 202-962-3249
MWCOG.org
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http://www,mwcog.org/news/press/detail.asp?NEWS ID=283 2/15/2008

# Air Quality MWAQC Releases New Air Quality Plan for Comment January2008
- the Metropolitan Washington Air Quality Committee (MWAQC) has approved for comment an air quality plan to reduce fine particle pollution in the region. Fine particle pollution is a mixture of microscopic solids and liquid droplets suspended in air. At 2.5 microns in diameter, the small particles can get deep into lungs and even the bloodstream. People with heart or lung disease, older adults and children are at greater risk from this type of pollution. View the press release for more detail. The states' comment period will end with public hearings in the region January 28
- February 11. View the flyer for exact times. The plan is available on the COG website for review. Comments may be submitted via e-mail.

## Maryland Department ofthe Environment

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## Citizen Alerts Maryland.gov 

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Contact Us Work With MDE 

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### .Press.Releases**~** Rese.arch Center Water**WQr~JI1QE** 

## MDE Meetings, Hearings" Events This site provides a listing of meetings, hearings, and other events pertinent to the functions of the Maryland Department of the Environment (MDE). Each scheduled meeting, hearing or event has a description, where at the minimum, the time and location are listed. Events that have been or will be cancelled or postponed are also noted.

. You may submit an event for posting on this site. However, its publication is at the option of the calendar administrator. Click the links at the right to go the calendar. 

### Featured Events:**~emi=An!lUII.C;omm.YI1ity.Ad.y.L$ory_GrouR.tC;AGl**

### Meetingfor.tbe

...env.i.rQnmeotal C.LU!lUP

.**.ll.tbe.(;_un.(L1,!anLYar.d~Yrti.$.J;lay.** Monday, January 28, 2008 

### P:ubllc

....tfear.in.a

..**~;m.Jt**..

### statelmgle.ment.aUonPlan

...(sIPlfor

..f:!ne

...Partlcylate..(PM**~.5.1standardfQrW.lShi.ngtQn.PC:::M.P:"ANQn....attainme!'!lArea** Wednesday, January 30, 2008 

### Sewage sludge Utilization PermitforSynagro Central, LLC Wednesday, January 30, 2008 

### Aberdeen Proving GrOJJnd Re.&tormo.D.,Advisory.Board Thursday, January 31, 2008 7:00 p.m. - 9:45 p.m. 

### PJJbJictfearing

...No!'!tid_aJ_\/IIetlandsPermit APpJication- Food Rite grocery store at MiUerGarage_Propefty Monday, February 4,2008 

### Air Quality Permitto Construct Inf()rmational Meeting for Dominion Cove Point for 2 Boilers Tuesday, February 5, 2008 

### Public Hearing

- Renewal ofState DischarQe...PerooLt foube Sudlersville wastewaterTreatment.Plant Wednesday, February 6, 2008 

### Governo.r'1iJ••**ead~PoiSJmm~e.ll.en.tjOJLCOmmlssion** Thursday, February 7,2008 

### Public Hearing on Tentative Determination to Rei$$uE! the General Di$charge 

# •

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D



## htto:ffwww.mde.state.md.us/calendarl 1/3012008

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# ~ 

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. ----- - . -- --. 

### Date: Wednesday, lanuary 30, 2008 Location: Maryland National Capitol Parks and Planning Commission, Fist Floor Auditorium, 8787 Georgia Avenue, Silver Spring, MD 

### Organizer: ARMA, MDE 

### Contact name: Randall Carroll 410-537-3252 

### Contact email: .a;arrol@mde.state.md.us 

### Contact address: Maryland Department of the Environment 1800 Washington Boulevard Baltimore, MD 21230 

### Description: Public Hearing on a State Implementation Plan (SIP) for Fine Particulate (PM 2.5) Standard for Washington DC-MD-VA Nonattainment Area.

About MOE The meeting will start at 6:00 PM.

Site Index Privacy Notice 1800 Washington Blvd, Baltimore, MD 21230 Tel:(410) 537-3000 Toll Free:(800) 633-6101 Accessibility Translate

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### I All rights reserved. 

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http://www.rnde.state.rnd.us/calendar/event.asp?id=1426&cid""20&rfrarne=0 1130/2008**~DE** 

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## MDE Public Meetings, Hearings and Request for Comments A list of MOE's public meetings and hearings are available In the MpgCaJendar. 

### Please call or email contact person cited In meeting details for materials for comment and other questions.



### .. Public Hearings Concerning Proposed New Air Quality Regulations and Amendments The Maryland Department ofthe Environment gives notice of public hearings concerning proposed new air quality regulations and amendments. The proposed actions are briefly described below: (1) adopt new Regulation .32 under COMAR 26.11.19 Volatile Organic Compounds from Specific Processes to establish volatile organic compound (VOC) emission limits and standards for the commercial application of coatings and non-coating materials to wood products. The regulation codifies limits consistent with those In existing air quality permits (Ie.chnlcaLSupportQQCUIDent); and 2) amend Regulation .30 under COMAR 26.11.19 Volatile Organic Compounds from Specific Processes, and adopt new Regulations .01
- .07 under a new chapter, COMAR 26.11.35 Control of Emissions of Volatile Organic Compounds from Adhesives and Sealants to establish emissions limits for adhesive application and manufacturing operations under COMAR 26.11.19.30 and VOC standards for over 40 categories of adhesives, sealants, adhesive primers, sealant primers and cleaning solvents under new COMAR 26.11.35 C'(echnicilISUPpo.rtQQ(;!.IIDellt). These actions will be submitted to the U.S. Environmental Protection Agency for approval as revisions to Maryland's State Implementation Plan. The full text of these new regulations and amendments will appear in the Maryland Register and at http://www.dsd.state.md.us/m..JiJ:eglstill on December 21, 2007. The proposed actions and supporting documents are also available for review at the following locations: the Air and Radiation Management Administration; regional offices of the Department in Cumberland and Salisbury; all local air quality control offices; 

### and local health departments in those counties not having separate air quality control offices. Public hearings on the proposed actions 

### will be held on January 23, 2008 at 10 a.m. at the Department of the Environment, 1800 Washington Boulevard, 1st Floor Aqua Conference Room, Baltimore, Marvland 21230-1720. 

### Interested persons are invited to attend and express their views. Comments may be mailed to Deborah Rabin, Regulations Coordinator, Air and Radiation Management Administration, Department of the Environment, 1800 Washington Boulevard, Suite 730, Baltimore, Maryland 21230-1720, or emailed to**drabin@mde.st.ate.mQ,J.!~,** 

### or faxed to (410) 537-4223. Comments must be received not later than January 23,2008, or be


## http://www.mde.state.md.us!AboutMDE!reqcomments.asp 113012008

### t

..

## 1DE Requestfor Comments Page 2 of4

submitted at the hearing. For more information, call Deborah Rabin at (410) 537-3240. Anyone needing special accommodations at the public hearing should contact the Department's Fair Practices Office at (410) 537-3964. TTY users may contact the Department through the Maryland Relay Service at 1-800-735-2258.
)0> 

### Public Hearing Concerning the Proposed New Particulate Matter (PM2.5) 

### Air Quality Plan Washington DC-MD-VA NOriattalnment Area The Maryland Department of the Environment gives notice of public hearing concerning the proposed new air quality State Implementation Plan addressing the Annual Fine Particle (PM 2.5) Standard. The proposed plan and public hearing is briefly described below: The proposed plan is titled the State Implementation Plan (SIP) for Annual Fine Particle (PM 2.5) Standard and 2002 Base Year Inventory for the Washington DC-MD-VA Nonattainment Area. The Washington DC-MD-VA Nonattainment Area includes the following Maryland counties: Charles, Frederick, Montgomery, and Prince George's Counties. The plan contains emission inventories, control measures, an attainment demonstration and motor vehicle emission budgets. This plan contains the base year 2002 air pollutant emissions inventory and 2009 projected inventory, which serves as the baSis for all planning activities related to the Annual Fine Particle Standard for the Washington DC-MD-VA Nonattainment Area. The Public Hearing 

### will be held on January 30, 2008 at 6:00 p.m. at the Maryland National Capitol Park and Planning CommiSSion, First Floor Auditorium, 8787 Georgia Avenue, Silver Spring, Maryland. 

### The SIP document has been made available on the Maryland Department ofthe Environment's webSite at http;/lwww.md..e .•state.md.us/PrQgrarns/AirPrograms.lalcpJanning/i.ndex.asp titled the "Plan to Improve Air Quality in the Washington, DC-MD-VA Region." For more information contact Randall Carroll, Air Quality Planner, at (410) 537-3252 (Toll free in Maryland call (800) 633-6101 ext. 3252) or**~roll@mde.stat.e.,m!i.Y.s.**



### .... Public Hearing Notice on Tentative Determination to Issue Permit The Maryland Department of the Environment (MDE) has reached a tentative determination to reissue the Ger:!.eral Discharge Pgrmit for Storm Water**D~ar.ggs ~ociated**  

### with Construction Activity, MDR10 (General Permit)

. A public hearing 

### will 

### be held on Tuesday, February 12, 2008 at 10:00 a.m. at the Maryland Department of the Environment Aqua Conference Room, 1800 Washington Blvd., Baltimore, Maryland, 21230 . 

### The permit is necessary to meet federal and State reqUirements under Code of Federal Regulations 40 CFR 122.26 and Code of Maryland Regulations COMAR 26.08.04.09A and to protect water quality. It 

### replaces the General Permit issued in March 2003. All construction activity in Maryland disturbing one or more acres need to be covered under the General Permit. The General Permit establishes effluent limitations in terms of performance standards associated with the Best Available Technology (BAT) for erosion and sediment control and storm water management. Compliance with the BAT aSSOCiated with the laws and regulations Cited in Part II A. of the General Permit will constitute compliance with effluent limitations for storm water discharges aSSOCiated with construction activity. No changes are proposed to the current permit and the fees for permit coverage are proposed to remain the same. Persons who wish to present information regarding the tentative determination may speak at the public hearing, submit written comments at the public hearing, or submit a written statement to the Deparment no later than February 27, 2008. All comments will be considered in the preparation of a final determination. Written comments should be addressed to the Maryland Department of the EnVironment, Water Management Administration, 1800 Washington Blvd., Baltimore, Maryland, 21230-1708, Attn: Karen 

## http://www.mde.state.md.us/AboutMDE/reqcomments.asp 113012008

## Air Quality Planning Page 1 of7


## Citizen Alerts Maryland.gov Online Services St

Contact Us Work With MDE 

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.. StateJmplementationPlans

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### State Implementation Plans Maryland's air quality plans, also called state implementation plans, are designed to attain and maintain the National Ambient Air Quality Standards, and to prevent significant deterioration of air quality in areas cleaner than the standards. Maryland's State Implementation Plans are viewable in Adobe Acrobat Reader (pdf) format. To view the documents, you will have to download the Adobe Acrobat Reader. 

### Document: State Implementation Plan (SIP) for Annual Fine Particle (PM2.5) Standard and 2002 Base Year Inventory for the Washington DC-MD-VA Nonattainment Area Draft for Public Comments Date: December 17, 2007 Click here to download 

### Document: Implementation, Maintenance, and Enforcement Measures for the 8-Hour Ozone National Ambient Air Quality StandiJIrd State Implementation Plan (SIP) Date: June 15, 2007 Click 

### here to download. 

### Document: Baltimore Nonattainment Area 8-hour Ozone State Implementation Plan and Base Year Inventory June 15, 2007 Sll'_DoQ"unenl: (6.7 MB) Appendix A Appendix A2 (1.2 MB) AppendixM (429 KB) Appendix A4 (280 KB) Appendix AS (710 KB) Appendix A6 (878 KB) Appendix B (194 KB) APp-endix C (823 KB)**Ap-p~ndix** D (92 KB) Appendix E APp-endb(!;l (330 KB)**Ap-p~dix.E2** (59 KB) Appendix F

### ApQendix-.--f:r1Qbile..sou['~EmlssLQnJ'e~hnl!:aLSupp~r:t

### Docume.llt (232 KB)**AQ~ndi~(L::.J!1put** ParameleLSummary (57 KB)



## htto:llwww.mde.state.md.uslProgramsl AirProgramslair planning/index.asp 

## 113012008

## , Shared Documents Page 1 

## of 1



## _ Air 

## Quality Files This Ust: Shared Documents Air Quality Files> Shared Docu ments > PM2.5 SIP 

# Shared Documents a document with the team by adding it to this document library.

WI Appendices 11/30/2007 4:56 PM Raymon Murchison 

# m Cover and Table of Contents 12.12.07 12/19/2007 11:22 AM Jeffrey King 1 

# m Chapter 1 Executive Summary 12.12.07 12/19/2007 9:54 AM Jeffrey King 3 

# m Chapter 2 Fine Particles 12.12.07 12/19/2007 9:55 AM Jeffrey King 4 

# m Chapter 3 BY 2002 EI 12.12.07 12/19/20079:56 AM Jeffrey King 5 

# m Chapter 4 AY 2009 El12.12.07 12/19/20079:56 AM Jeffrey King 6 

# m Chapter 5 Control Measures 12.12.07 12/19/2007 9:57 AM Jeffrey King 7 

# m Chapter 6 RACM Chapter 12.12.07 12/19/2007 9:57 AM Jeffrey King 8 

# 11 Chapter 7 Mobile Budgets 12.12.07 12/19/2007 9:57 AM Jeffrey King 9 

# m Chapter 8 Commitments 12.12.07 12/19/2007 9:57 AM Jeffrey King 10 

# m Chapter 9 Attainment Modeling 12.12.07 12/19/2007 9:58 AM Jeffrey King 

### 11 

# m Chapter 10 Contingency 12.12.07 12/19/20079:58 AM Jeffrey King 12 

# m GLOSSARY OF TERMS AND ACRONYMS 12.12.07 12/19/20079:58 AM Jeffrey King 13



## http://sharepoint.mwcog.org/airquality/Shared%20Documents/Forms/AllItems.aspx?RootF...l/30/2008

### Page 

## 10f2


## Citizen Alerts Maryland.gov Online Services St

Contact Us 

### Work With MDE 

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# II

About MDE 

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...**ReJe.as~ ~**  

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## Calendar of Events

Public Informational Meetings and Hearings 

## Public meetings called by MDE to discuss permit applications, tentative determinations and renewals, as well as to receive comments on proposed amendments to regulations and other environmental concerns. [P f.euious Hon.tb

# I January**~--n** ' ,- -- . t""lJiijill 

## 2008 Sunday Monday

6 7

13 14 

### Tuesday

8 

### P\,tbU(; Mee.tingQo the. ne.IN dra.ft

..

### Qftll.e revised 

### MD Se.INgge 

## Slud.9-e RegyJatJoJ!s

15 

### Wednesday Thursday 2 3

9

16 

### InformittJon publl/; meeting to discuss CHS permit 

### Rene_waL for 

## Aberdeen P[ov:iOg 10 

### Info.[ITl<.ltioo meeting.

## to dJscuss.2 refuse 

### IDs.QQsa1 permit**aQQU~ations** 

### fQrthe Beulgh landftU**~QH!;Lwj'!.ste** 

### Facllityjn 

## P.ofcbesteJ: county

... 17 

### Friday Saturda' 4

11

18



### http;!!www.mde.state.md.us/calendar/calendar.aso?cid=20&tvoe=O&date=1%2F1%2F200R 11

### I)1100RContact Us 

### 20

27

About MDE 

### 21

28 GrQund. 

### 22 23 Public Public IieMI!l9....QD Hea

### rln!l.=**Jlli)~.d** NontldaJ amendments Wetlands 

### tQJlli 

### flllinlt 

### [@lJ.lati.!ms &:mlkatiruL: induJiing 

### !.L.S..M.rn¥ n.e'lL!![otocQ] 

### GarrisQD regulqj:iQ!lS. 

### eubllc**l::learirlg.re~** Procedures 

# mr ferf'orming**~d** AbatemeJll Services 29**~blli;** I::LeaIing Concerning Proposed New 

### Air Q.uRlit¥ Regulations and Amendments 30 

### EUbilc HearingQna State Implementation 

### pll',ln (SIP) foeFine Particulate 

### CPM2.5) Stand.ard ·for WqShington DC-MD-VA Nonattainment Area**~ Slu~** **Utlli~atlcm** 

### Eer!::rlJUQr SYDagIQ**~~-'.LC** 

### 24

31

Site Index Privacy Notice Accessibility 1800 Washington Blvd, Baltimore, MD 21230 Tel:{410) 537-3000 Toll Free:{800) 633-6101 Maryland Department ofthe Environment 

### I ©Copyrlght 2002-2008 

### I All rights reserved. 

## Page 2of2

25

Translate



### httn'llwww 

## mclestate.mcl.us/calendar/calendar.aso?cid=20&tvpe=0&date=1%2Fl%2F2008 2115/2008

# OpeningRemarks PublicHearing on State Implementation Plan (SIP) ForAnnualFine ParticlePM

# (2.5) Standard Date: January 30, 2008 Randall Carroll, Hearing Officer MarylandDepartment of the Environment, James Wilkinson



# Ifthe courtreporter would turn 

# on the equipment, we will begin. Good Evening. Onbehalfofthe Maryland Department ofthe Environment, Air andRadiation Management AdministratioIi, I would like to welcome everyone present to this public hearing. This public hearing is being held pursuant to federal law found at 42 U. S. C. 

# § 7410(a) and 40 CFRParts 51.102 and 251. It 

# is also being held in conformance with the State Administrative Procedure Act, under the State Government Article, beginning at Section 10-101.

Notice ofthis public hearing has appeared in the Washington Post Newspaper on December 27,2007 and the Washington ExaminerNewspaper on December 27, 2007.

Notice was also posted on the Maryland Department ofthe Environment web site commencing on December 27,2007 and the Metropolitan Washington Council of Governments website on December 12, 2007.

# Myname is Randall Carroll. I am an air quality planner with the Air and Radiation Management Administration's Air Quality Planning Program. I will

serve as hearing officer this afternoon.

First, I would like to ask all in.attendance to please sign-in at the back, ifyou haven't already done so. This will help us to keep an accurate record ofthe people who participate in ourproceedingshere today. Also, a full copy ofthe proposed Annual Fine Particle 

# (PM2.

# s) SIP and 2002 Base Year Inventory and additional support material are available on the back table for your information.

This hearing is related to the Washington DC Region Annual Fine Particle (PM2

# .5) 

# Standard State Implementation Plan and Base Year Inventory. Thisplan is

a comprehensive document that details how the region plans to attain the Federal Fine Particle Standard.
The hearing will proceed in the following order. First, Mr. James Wilkinson

an Air Quality Planner with the Air Quality Planning Program ofthe Air and Radiation Management Administration will read the Department's statement into the record.

## After Mr. Wilkinson is finished reading the Department's statement, I will first call on any elected official orgovernment official who wants to make a statement. Then, I will call upon anyone else who indicated on the sign-in sheet that he or she would like to make a statement.

When giving your statement, please come up to the table, identify yourself and your affiliation, and give your statement loudly and clearly so the court reporter is sure to catch your words. Hearingprocedure does not call for question and answer sessions. Statements recorded at this hearing eventwill be answered in writing andpublishedwiththe fmal State Implementation Plan document. Are there any procedural questions?



# Once all questions have been taken -- ifthere are any -- you are ready to begin.

Ifthe courtreporterwouldbeginwe will go onrecord to receive comment. Mr. James Wilkinson will proceed withthe Department's statement. Again, there

are copies onthe back table you mayuse to read along.



# 3

# (While Jim reads his statementyou get up and walkto the back andpickup the sign in sheets. You are looking to see who said they would like to make a comment. When he is finished his presentation,you thankhim and lookto call

on any elected officials who wanted to make a statementfirst. Ifthere are no elected officials, you call on the first person that wanted to comment.)

I will now call on______ _ 

# After calling on all those who wanted to make a statement say the following: Now is there anyone who would like to make a statement, but did not indicate so on the sign-in sheet?



# (Ifno one wants to make statement say:) No one has indicated that they wish to make a statement, is there anyone who would nowlike to make a statement, even ifthey did not indicate so on the sign-in sheets.



# (After all statements have been presented, say) Let the record reflect that a statement hasbeen taken from all who wish to make one. This will conclude this public hearing. Let the recordreflect that it is



# 4

# now (The correct time) o'clock and this hearing and record for public comment

on the State Implementation Plan (SIP) for Annual Fine Particle (PM2.S) 

# and 2002 Base Year Inventory now officially stands closed at the end ofthese proceedings

onJanuary 30, 2008.



# PUBLIC HEARING 

# WHAT TO SAY IF NOBODY SHOWS FORTHE HEARING

• WAIT AT LEAST 30 MINUTES BEFORE YOU DO 

# ANYTHING !II


# IF THE COURT REPORTERWOULD PLEASE TURN ON THE NECESSARY EQUIPMENT. LET THE RECORD SHOW THAT the time is now XXX o'clock on January 30, 2008. This hearing was scheduled for a 6:00 pm start time. There are currently no persons in the audience wishing to make any statements on the record so we request that the court reporter please enter the hearing statement into the record at this time. The official commentperiod for the document ofrecord is
now closed. This public hearing is now closed.

L:\AQPlanning and Monitoring\Planning Division\Air Quality Plans (SIPs)\PM2S\MWCOG\PM Documents\PM Opening Statement-.doc


# 5

## Statementofthe Air and Radiation ManagementAdministration Maryland Department ofthe Environment For the Public Hearing Concerning State Implementation Plan (SIP) for Annual Fine Particle (PM2.S) Standard and 2002 

## BaseYear Inventory for theWashington DC-MD-VA NonattainmentArea Held on January 30, 2008

Good Afternoon. My name is James Wilkinson. I am a Planner inthe Air QualityPlanning Division, 

## Air QualityPlanning Program ofthe Air & 

## Radiatio.n Management Administration, Maryland Department of Environment. This public hearing is related to the airqualityplan titled the State ImplementationPlan for the Annual Fine Particle Standard and 2002 BaseYearInventory for the WashingtonDC-MD-VA Attainment Area. This public hearing is being held pursuantto federal law found at 42 U. S. C. 

## § 7410(a) and 40 CFRParts 51.102 and 251. It

## is also being held in conformance withthe State AdministrativeProcedure Act, under the State Government Article, beginning at Section 10-101. Notice ofthis public hearing appeared in the:

• Washington Post on December 27, 2007 • The ExaminerNewspaperpublished onDecember 27,2007 • Maryland Department ofthe Environment website onDecember 27,2007 • Metropolitan Washington Council ofGovernments website on December 12,2007 Copies ofeach ofthepublic hearing notices and the Proposed State ImplementationPlanfor the Annual Fine Particle Standard and 2002 Base YearInventory for the Washington DC-MD-VA Attainment Area willbe part ofthe formal hearing record. Access to the proposed document was made available viathe websites ofboth the Maryland Department of the Environment and the MetropolitanWashington Council ofGovernments. Hard copies were also available at the Maryland Department ofthe Environment and the Metropolitan Washington Council of Governments. Thepurpose ofthis hearing is to provide the public with an opportunity to formally comment on the proposed document. 

## Summary ofProposed State Implementation Plan for theAnnual FineParticle Standard The Clean AirAct Amendments of 1990 represent an unprecedented commitment to protecting public health and the environment. A high level offine particles is a healthproblem. Fine particle pollution is a mixture ofmicroscopic solids and liquid droplets suspended in the air. At 2.5 microns in diameter, the small particles can get deep into lungs and even thebloodstream. People withheart or lung disease, older 1

## adults and children are at greaterrisk from this type ofpollution. 

## It is especiallyharmful for those with respiratory problems such as allergies, asthma, bronchitis and emphysema; and greater susceptibilityto respiratory infection. On March 29, 2007 EPA finalized the Clean AirFine Particle hnplementation Rule defining requirements for stateplans to meet the 1997 National Air Quality Standards for fine particle pollution. Monitored levels offine particle pollution have been declining in the Washington DC region since 2005. Underthe proposedregional plan as released here for public comment, these levels are expected to continue to decrease. Although the region has complied with EPA's annual fine particle standard, the regional states ofMD-VADC have prepared a planto further reduce level offine particles by 2009. Through the purchase ofwind power energy, green buildings, improved energy efficiency and increasing the tree canopy in the region, local governments are helping reduce air pollution. EPA designated the metropolitan Washington region as a nonattainment area for annual fine particulate matter inJanuary 2005. The region has demonstrated compliance with the annual PM2.5 standard for the last several years. The geographic scope oftheregion includes several Maryland Counties including Montgomery, Prince George's, Frederick, and Charles County. This document, the State hnplementationPlan for the Annual Fine Particle Standard and 2002 Base Year Inventoryfor the Washington DC-MD-VANonattainment Area is a planto improve air quality inthe Washington region to meet the National Annual Fine Particle Standard. The Plan consists ofBase Year inventories for 2002, projection inventories for 2009, an attainment plan, a demonstration ofreasonable available control measures, motor vehicles emission budgets for 2009 and 2010, an attainment demonstration, and contingencyplans for attainment. The planhasbeen prepared by the Metropolitan Washington Air Quality Committeeto comply withthe Clean AirAct Amendments of 1990 and withEPArequirements for the Washingtonregion as stated in EPA's 2005 designation ofthe Washington region and EPA's Clean AirFine Particle Implementation Rule. CONSIDERATION OF COMMENTS 

## The Department will consider all pertinent comments, and revise the proposedplan ifnecessary, before making a final decision to adopt the plan and submit it to the U.S. EnvironmentalProtection Agency for approval as a Maryland State hnplementationPlan. Written comments maybepresented at this hearing butcannotbe accepted ifnot presented before the close ofthe hearing. The 30-daypublic comment period that began on December 27, 2007 for receipt ofall comments to the plan will close at the end ofthis public hearing.

2

# ORIGINAL

1 1 

## 2 3 

## MARYLAND DEPARTMENT OF THE ENVIRONMENT 4 

## 1800 WASHINGTON BOULEVARD 5 

## BALTIMORE, MARYLAND 21230 6 7 

### 8 

## Public Hearing 9 

## On State Implementation Plan (SIP) 10 For Annual Fine Particle PM (2.5) Standard 11 12 Hearing Officer: Randall Carroll 13 14 15 The above-entitled public hearing was held at the 16 Montgomery National Capitol Park and Planning 17 Commission, 8787 Georgia Avenue, Silver Spring, 18 Maryland, on January 30, 2008, and commenced at 6:27 19 p.m. 20 21 

## 22 Recorded by: Frank Quinn 

# For The Record, Inc. (301) 870-8025 www.ftrinc.net - (800) 921-5555

## 2 1 

## ATTENDEES 2 

## Randall Carroll, Hearing Off , MOE 3 

## James Wilkinson, Natural Resources anner, MOE 4 

### 5 

## 6 7 8 9 

## 10 11 

## 12 

## 13 14 

## 15 

## 16 17 

## 18 19 20 21 

## 22 

# For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555

### 1 

## 2 3 4 

### 5 6 7 

### 8 9 

## 10 11 

## 12 13 14 

## 15 16 

## 17 18 

## 19 :20 21 

## 22 3 

## PRO C E E DIN G S

HEARING OFFICER CARROLL: Let the show that the time is now 6:27 p.m. on January 30, 2008. This hearing
was scheduled for a 6:00 p.m. start time. There are currently no persons in the audience wishing to make any statements on the record, so we request that the court reporter please enter the hearing statement, given to him earl r, into the record at this time. The official comment period for the document of record is now osed. This public hearing is now closed. For the record, my name is Randall Carroll, Hearing Officer. Thank you. (Whereupon, the was hearing concluded at 6:29 p.m.)



# For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555

### 4 1 

## CERTIFICATE OF COURT REPORTER 2 3 

## I, Frank Quinn, do hereby certify that the 4 

## foregoing transcription was reduced to typewriting via 5 

## audiotapes recorded by me; that I am neither counsel for, 6 

## nor related to, nor employed by any of the parties to the 7 

## case in which these proceedings were transcribed; that I am 8 

## not a relative or employee of any attorney or counsel 9 

## employed by the part s hereto, nor financ lly or otherwise 

## 10 interested in the outcome of the action. 11 

## 12 13 

## FRANK QUINN, COURT REPORTER 

## 14 15 16 17 18 19 

## 20 21 22 

# For The Record, Inc. (301) 870-8025 - www.ftrinc.net - (800) 921-5555

# MDE MARYLAND DEPARTMENT OF THE ENVIRONMENT AIR AND RADIATION MANAGEMENT ADMINISTRATION

SUBJECT: PUBLIC HEARING

- PROPOSED STATE IMPLEMENTATION PLAN (SIP) AND 2002 BASE YEAR INVENTORY FOR THE WASHINGTON DC-MO-VA PM2.S NONATTAINMENT AREA DATE: January 30, 2008
_."------ ---_._._._._.'.,._----
- 

## Name Signature Address City and Organization or Do You Wish (please print) Code Affiliation To Testify?

# Q/~ {l)c..J**~p**

# --./tfflJ.I.n., 

# S,lv",... S

# fl.r.'-j. 

# A-'G PA-L. 

# N '-: ,'l\

# Ees-e\-(0c' 

# A:v--e**-,~** 

# D

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## .... p Lc.J**~** 

## lO

### Martin 

### 0 'MallIfY Governor 

# Mary/andDepartmentof Planning

Anlho'!Y

### G. Brown l.J. 

### Governor



### Mr. Randall Carroll January 17,2008

Air Quality Planner, Air and Radiation Management Administration Maryland Department ofthe Environment 1800 Washington Boulevard Baltimore, MD 21230 STATE CLEARINGHOUSE REVIEW PROCESS

State Application Identifier: MD10071217-1133 RichardEberhartHall 

### Semlary Matthew

## J. Power 

### Deputy Semlary



### Project Description: Draft State Implementation Plan for Annual Fine Particle (PM2.5) Standard and 2002 base Year Inventory for the Washington DC-MD-VA Nonattainment area: public hearing 1/30/2008 Project Location: States ofMaryland, and Virginia; and the District ofColumbia Clearinghouse Contact: Bob Rosenbush Dear Mr. Carroll: Thankyou for submitting yourproject for intergovernmental review. Participation in the Maryland Intergovernmental Review and Coordination (MIRC) process helps ensure project consistency with plans, programs, and objectives ofState agencies and local governments. Notice ofyour application is being provided to State and local public officials through the 

### IntergovernmentalMonitor, which is a weekly Internet publication identifying projects received by the State Clearinghouse for Intergovernmental Assistance. This document may be viewed at http://www.mdp.state.md.us/CLHOUSE/monitorfy04.htm. The project has been assigned a unique State Application Identifier that should be used on all documents and correspondence. All MIRC requirements have been met in accordance with Code ofMaryland Regulations (COMAR 14.24.04) and this concludes the review process for the above referenced project. Ifyou need assistance orhave questions, contactthe State Clearinghouse staff person noted above at 410-767-4490 orthrough e-mail atbrosenbush@mdp.state.md.us. Thank you for your cooperation with the MIRC process. Sincerely,

# ~t;~~ Linda C. Janey, J.D., Assistant Secretary for Clearinghouse and Communications LCJ:BR

cc: Kathleen Blinebury • U.S. Environmental Protection Agency 07-1233_NMNEW.doc



### 101 Wrs! Pm/on SImI.SlIile 

### 1101 • 

### Baltimore, Maryland21201-2)0) Telephone: 410.767.4500.Fax: 410.767.4480. TollFree: 1.877.767.6272 • 

### TrYUser'S: Maryland**Rt'~** 

### internet: www.MDP.Jlale.md.lIs

# (

( From: To: 

### Date: Subject: MARYLAND Randall Carroll clearinghouse@mdp.state.md.l.Is 

### 12/31/200712:48:50 PM MD Public Notice-PM SIP
PM2.5 SIP Public Notice and Release for Comment This is to notify you that the state of Maryland
- Maryland Department ofthe Environment has put forth a draft PM SIP for public review and comment. The PM SIP was released to the public by legal notice on Thursday, December 27,2007 for the regulatory 30-day period of public comment. The PM-SIP is entitled: The State Implementation Plan (SIP) for Annual Fine Particle (PM2.5) Standard and 2002 Base Year Inventory for the Washington OC-MO-VA NonattainmentArea. A Copy ofthe newspaper notice is attached foryour review.



# cc: Rcarroll@mde.state.md.us

# ( From: Randall Carroll 

## To: Allehany County Health Officer; Anne Arundel Health Officer; Baltimore City Health Officer; Baltimore County Health Officer; Calvert County Health Officer; Caroline and Kent County Health Officer; Carroll County Health Officer; Cecil County Health Officer; Charles County Health Officer; Dorchester County Health Officer; Frederick County Health Officer; Garrett County Health Officer; Harford County Health Officer; Howard County Health Officer; Montgomery County Health Officer; Prince Georges County Health Officer; Queen Annes County Health Officer; Somerset County Health Officer; St Marys County Health Officer; Talbot County Health Officer; Washington County Health Officer; Wicomico County Health Officer; Worcester County Health Officer 

### Date: 12/20/20071:03:21 

### PM 

### Subject: Md County Health Officers County Health Officers: Attached please find the public hearing notice for the Maryland PM 2.5 State Implimentation Plan (SIP) scheduled for the Maryland Counties in the metropolitian Washington region. This hearing will be held on January 30, 2008 in Silver Spring, Maryland.

# All County Health Officers Members To: Allehany County Health Officer To: Anne Arundel Health Officer To: Baltimore City Health Officer To: SaltimoreCounty_Health Qfficer To: QalvertCountyHealth Officer To: CarolineancjKent CouotyljealthOfficer To: CarroU CQuntyHealth Qfficer To: Cecil County HeaJthQfficer To: Charle$.Countytlea!th Officer To: OOIche§ter CountyJ:ieaJth.Qf{icer To:**Fr~perick** 

# County J:-iealth Office( To: Garrett County Health Officer To:**tiarfor~Co~tnt~Health** 

# Officer To: Howard County Ijealth Officer To: Montgomery County Health Officer To: Prince Georges County Health Officer To: Queen Annes County Health Officer To: Somerset County Health Officer To: St MarY$CountyHealthQf{icer To: Talbot County Health Officer To: vva§oJngtonCountyHealthQfficer To: Wicomico County Health Officer To: VVorcester CouotyHeaJthOfficer

file:1Ie:

## \Documents and Settings\rcarroll\Local Settings\ T emp\gwa60.tmp.html Page 1of 1

2/19/2008

## a

From: Randall Carroll 

## To: Allegany County Environmental Health Director; Anne Arundel County Environmental Health Director; Baltimore City Environmental Health Director; Baltimore County Environmental Health Director; Baltimore County Environmental Health Director 

### 2; Calvert County Environmental Health Director; Caroline County Environmental Health Director; Carroll County Environmental Health Director; Cecil County Environmental Health Director; Charles County Environmental Health Director; Dorchester County Environmental Health Director; Frederick County Environmental Health Director; Garrett County Environmental Health Director; Harford County Environmental Health Director; Howard County Environmental Health Director; Kent County Environmental Health Director; Montgomery County Environmental Health Director; Montgomery County Environmental Health Director 

### 2; Montgomery County Wells and Permits; Prince Georges County Environmental Health Director; Queen Annes County Environmental Health Director; Somerset County Environmental Health Director; St Marys County Environmental Health Director; Talbot County Environmental Health Director; Washington County Environmental Health Director; Wicomico County Environmental Health Director; Worcester County Environmental Health Director 

### Date: 

### 12/19/20075:04:11 PM 

### Subject: MD
- PM State Implimentation Plan County Environmental

# Health~:**{)(flH..~(l~** Attached please find the public hearing notice for the Maryland PM 2.5 State Implimentation Plan (SIP) public hearing scheduled for Maryland counties in Metropolitan Washington area. This hearing is to be held on January 30,2007 in Silver Spring, MD.

# All County Environmental Health Directors

Members**~---** 

# To:**Alleg~nyJ;o-'-'loJy**

# ....**Environmeol~Jtte~ltbJ::>ireclor** 

# To: An**neAryndeICQuntyEnvirOJlm.enl~JHe~ltbPiJector** 

# To:6allimQJeCityEnVi[Onmental tteallhPirector To: 13aHimoreCOYl1tyEnyirOnmenlaJHealJbPirector To:6altimO[e

...CounlyEl1yirO nmenlalHealtb.DjreclQJ2 To: Calvert County EllvironmentaI Health Pirector To: Caroline County Environmental Health Director To:**CarroUJ~ountY.En_vironmental** 

# Health Director To: Cecil County Environmental**He~lth** 

# Director To: C_harles County Environmental Health Director To: Dorchester County Environmental Health Director To: Frederick County Environmental Health Director To: Garrett County Environmental Health Director To: HarfQrd CQuotyEnViroomentaI HeaJthOirecl0r To: HowargCouotyEnvi[onmentCiIHealth

.. PJrector To: Kent County EnvironmentaJHealthPirectQr T0: 

# Montgomery COLJntyEnVironmentalHealtl]Oirector To:**MontgomeryCountyE;nvironmentClIHe~lthOirec;tor**

# 2 To: Montgomery**COLJntyWeU§~ngPermits** 

# To: Prince GeOrge$CoYntyEnvi[oomentaIHealthDirector To: QueerLAnnes County EnvironmentaltiealthJ)irector To: Somerset County Environmental Health l)irector To:**~j Ma~Gounty**  

# Environmental Health Director To: TalgotCQunJyJ;nvironmental**He~lth** 

# Director To: Washington.County Environmental Health Director To: Wicomico. County Environmeotal Health Director To: Worcester_County**Enviro~mental** 

# HealttLDireclOI

file:IIC:\Documents and Settings\rcarroll\Local Settings\Temp\gwa62.tmp.html Page 1 of 1

2/19/2008

# (

( From: To: Date: Subject:

### ALLRandall Carroll Cecily (DDOE) Beall; Doris McLeod; Jeffrey King 

### 12/27/20079:50:17AM Re: Reminder
-- Need Newspaper Notices
Md notice of public hearing for the PM SIP should appear in today's newspaper- Dec 27, 2007 Washington Post 

### * Montgomery Co. zone - Montogemery, Frederick, Howard, Baltimore Cos. 

### * Prince Georges Co. zone- Prince Georges, Southern Md, Anne Arundel The hearing will be held on Jan 30, 2008 at 6:PM at the M-NCPPC in Silver Spring, MD (see attached)

### From: Randall Carroll To: ali.mirzakhalili@state.de.us; Debbie Rabin; jepps@state.pa.us; JeSydnor@dew.virginia.gov; John Benedict; katz.judith@epa.gov; Linda Janey Date: 

### 12/31/200712:41:36 PM Subject: Notice of Public Hearing-PM2.5 Maryland MARYLAND PM2.5 SIP Public Notice and Release for Comment This is to notify you that the state of Maryland
- Maryland Department ofthe Environment has put forth a draft PM SIP for public review and comment. The PM SIP was released to the public by legal notice on Thursday, December 27, 2007 for the regulatory 30-day period of public comment. The PM-SIP is entitled: The State Implementation Plan (SIP) for Annual Fine Particle (PM2.5) Standard and 2002 Base Year Inventory for the Washington DC-MD-VA Nonattainment Area. A Copy ofthe newspaper notice is attached for your review.

### From: To: 

### Date: Subject: Randall Carroll mlogan@baltometro.org; Spink.Marcia@EPAgov; wilmapco@wilmapco.org 12/31/2007 

### 1:36:47 PM PM SIP Notification MPO email notification email notification ofMaryland Public Hearing
MARYLAND PM2.5 SIP Public Notice and Release for Comment This is to notify you that the state of Maryland
- Maryland Department ofthe Environment has put forth a draft PM SIP for public review and comment. The PM SIP was released to the public by legal notice on Thursday, December 27, 2007 for the regulatory 30-day period of public comment. The PM-SIP is entitled: The State Implementation Plan (SIP) for Annual Fine Particle (PM2.5) Standard and 2002 Base Year Inventory for the Washington DC-MD-VA NonattainmentArea. A Copy ofthe newspaper notice is attached for your review.



# cc: Shannon Heafey Pa

### From: Randall Carroll To: bill.o'sullivan@dep.state.nj.us; jhavens@state.pa.us; Morris.Makeba@epa.gov; ray.malenfant@state.de.us 

### Date: 12/31/20072:06:14 PM 

### Subject: PM SIP notification email notificaiton MARYLAND 

### PM2.5 SIP Public Notice and Release for Comment This is to notify you that the state of Maryland
- Maryland Department ofthe Environment has put forth a draft PM SIP for public review and comment. The PM SIP was released to the public by legal notice on Thursday, December 27,2007 for the regulatory 30-day period of public comment. The PM-SIP is entitled: The State Implementation Plan (SIP) for Annual Fine Particle (PM2.5) Standard and 2002 Base Year Inventory for the Washington DC-MD-VA Nonattainment Area. A Copy ofthe newspaper notice is attached for your review.

# --. MARYLAND DEPARTMENT OF THE

4

__ 

# ENVIRONMENT 

# MDE 1800 Washington Boulevard • Baltimore MD 21230 410-537-3000. 1-800-633-6101

Martin Shari T. Wilson O'Malley Secretary Governor 

### Robert M. Summers, Anthony Ph.D. Brown Deputy Secretary Lt. Governor



## PUBLIC COMMENT

Public Hearings in Maryland for the Washington Region's Air Quality Plan were scheduled and held atthe MarylandNational Capitol Park & 

## Planning Commission, 

## 8787 GeorgiaAvenue, Silver Spring, Md. on January 

## 30, 2008 at 

## 6:00 pm. At that time the public was afforded the opportunity to personally appear and express any concernwiththe" Fine Particle PM2.5 State Implementation Plan and 

## 2002 Base Year Inventory" for the Washington DC-MD-VA Nonattainment area. This SIP was released for public comment and review onDecember

## 27,2007. Priorto this hearing the public was urged to express their concerns viathe standard US Postal Service mail orby email submission. Every writtenmail response oremail comment received inMaryland on behalfofthe SIP was forwarded to the Metropolitan Washington Air Quality Committee (MW AQC) which served as the regional depository point for comments received throughout the region ofMaryland, Virginia and the District ofColumbia. Maryland received comments by mail or by email priorto the scheduledpublic hearing. All comments received atthe public hearing and prior have been responded to and appear in the composite "Response to Comments" section found inAppendix _K

__ofthe Appendix to the State ImplementationPlan (SIP) for Fine Particle (PM2.s) Standard and 

## 2002 Base Year Inventory for the Washington DC-MD-VANonattainment Area.MWAQC PM 2 .1 SIP 

### List of Comments Received on the Draft PM2.S State Implementation Plan for the Washington, DC-MD-VA Nonattainment Area Comment Commenter(s) Date Recipient • Number Received 1William Skrabak, on behalf of the City ofAlexandria 1/30/08 VOEQ 2Jeffrey Holmstead, Bracewell and Giuliani, on behalf 1/30108 VOEQ

of Miran! Potomac River LLC 3Jeffrey Holmstead, Bracewell and Giuliani, on behalf 1/30/08 MOE

ofMirant Potomac River LLC 4Ana Prados and Mike Town 1/29108 VOEQ

Sierra Club, Virginia Chapter 5 Flint Webb, Fairfax Federation ofCitizens 1/30/08 VOEQ

Associations 6Julie Crenshaw Van Fleet 1130108 VOEQ 7Air Quality Public Advisory Committee 216/08 MWAQC 8RogerWaud 217/08 OCOOE gTom Ballou, on behalfofVirginia OEQ 1/29/08 MWAQC 10 Marilyn Powers, U.S. EPA, Region III 1/30/08 VOEQ 11 Charley Baummer, on behalf of Metropolitan 1/30/08 VOEQ

Washington Airports Authority 12William Skrabak, on behalfofthe City ofAlexandria 2/11/08 OCOOE 13Jeffrey Holmstead, Bracewell and Giuliani, on behalf 2/11108 OCOOE

of Miranl Potomac River LLC 14Elizabeth Chimento 2/11108 OCOOE

Appendix K Attachment 1 - Page Number: 1 March 7. 2008Comment Summary and Response for Comments Received on the Draft PM2.5 State Implementation Plan for the Washington, DC-MQ..VA Nonattainment Areaa 

### ;**~** E.a Comment Commenter RKipieni Response 

## B oz General Comments on SIP 1 The SIP include reference 10 Ihe scienljfic community's insislance Elizabelh Chimenlo DCDOE The main purpose of this altainmenl plan continues 10 be demonstrating compliance with the 1997 standards of 15.0 that the annual 15 uglm'NMOS is laO high and should be reduced uglm' annually and 65 uglm'daily. FRM dala show lhalthe region has already atiained lhe 1997 slandards of 15.0 1o 13·14 ugIm' 10 be proiecUve of human heaUh. ugim' on an annual average and 65 uglm' on a daily average. 1I\Ihile lower levels of air poAulion are desirable. MWAQC and Ihe slales do nol agree lhal iI is appropriate to commenl on Whether the NMOS prollides a salisfaclory level of hUIfllll1 health protection in the attainment SIP. 2 The SI P should include additional infonnation on the health benefits JuUe Crenshaw VDEO, language has been added 10 the attainment plan \0 indica1e thai altainmenl ofthe PM,. NMOS. as weR asfurther air expected to accrue from implementation of lhe plan, including Ihe Van Fleet, AOPAC MWAOC quality improvements, wi. have a positive influence on the health and well-being ofthe cilizens of Ihe region. health impacts around the PRGS. The altainment plan requires thai PRGS perform an ambienl air qua"ty analysis when the methodology for such an analysis is finalized. The results ofthis sludy may show Ihat addilional controls on PRGS are needed 10 ensure the PM,. NMOS is mel. 3 ATSDR Health Consultations for RiverTerrace in the District and the Jutie Crenshaw VDEO MWAQC and the staleswin review and considerthe identified health consultation sludies. Potomac River Generaling Station in Alexandria should be reviewed. Van Fleet 4 The SIP should address the potenlial impact ofthe use of poRlllion Julie Crenshaw VDEO, MWAOC and the states do not believe that the aUainment plan is an appropriate place to enumerale details about a control addftives such as TRONA. Van Fleel, AOPAC MWAOC specific facilty's operalional considerations. Such delaOs are routinely examined and incorporated iolo**perm~s** through the normal permitting process. 5 Direct primary PM", emissions, while nol a large part ofthe inventory, AOPAC MWAOC MWAOC and the stales agree that in the future more attention needs to be paid 10 PM". emissions sources and are increasing and may need 10 be addressed in the future. emissions inventories. Much more federal guidance, including a more robust tesl results dala base and the resulting emission factors thai may be developed for 118rious source calegoriesfor Ihat dala base, needs to be prollided 10 stale and local agencies. This information needs 10 contain information on both filterable and condensable PM"" An area needing work is lhe area source emissions inventory. The chemistry of PM,. is slin being examined by EPA scientisls, and unlil more information is kno

...... about PM". formation, the relalive importance ofvarious area source categories, and the need for area source controls, cannot be adequately evalualed. 6 In Section 2.6, the OCMs and Ihe sulfates as mentioned and depicled AQPAC MWAOC MWAQC and the states agree that the science ralaled 10 OCM/aerosols and VOCs is rapidly developing. 1I\Ihile the are of greaterconcern ifconsidered cumulatively. Yel Ihere is no current plan shows howwe will altain the annual PM" standard changes in the PM". standard are eventual and Ihere wi. dialogue regarding them, and in Ihis same saclion the primary be a need 10 further develop our understanding ofthe complex science of PM"" However. for Ihe purpose of Ihis SIP Ihe aerosols, given the capacity to create new PM, should be clearly region has compleled a plan Ihal shows howthe region will meal the currenl annual slandard. explained. The term OCM should be included in lhe glossary. 7 Seelion 9.4.5 dubs .5 percent a "margin of safety:The SIP should AOPAC MWAQC The commenter appears 10 be referring to the statement in Section 9.4.5 thai notes, "EPA**mod~ng** guidance states thai dearly explain this percenlage andjustify its adequacy as a margin, those modeling analysesthat show Ihat attainmenl with the NMOS wi" be reached in lhe future wilh some margin of since jl may nol be adequale. safety (I.e., eslimallld concentralion below 14.5 uglm'for annual PM,.• and 62 uglm'for 24-hour PM",) need more limiled supporting material: The weight 01 evidence range, as suggesled by EPA guidance for the annual PM ,s standard of 15.0 uglm', is 14,5 uglm'



### MWAQC PM2 5 

### SIP Appendix K Attachment I

- Page Number: 2 March 7,2008

### it E.., Comment Commenter Recipient Response 

## H oz to 15.5 uglm. Should the design wlues predicted by the regional modeling fall into this range. EPA has provided guidance on what must be included in a weight of evidence showing 10 demonSlrate that allainment of the standard wll be achieved in 2009. Modeling results that fall beneath 14.5 uglm', such as those for melropolitan Washington, need a less comprehensive**~ght** ofevidence demonstration. Modeling, which indudes the additional suite of control measures prescribed by the 8- hour ozone allainment plan, projects the area's 2009 design value 10 be 13.9 uglm'. See Table 9-3 of Ihe draft PM,., attainment demonstration. Control Strateay/Menures S The states and the Melropolnan WaShington Council ofGovernments AOPAC MWAQC MWAQC and the slates agree and appreciak! the recognnion for the considerable progress being made to improve air for their consIderable efforts to reduce partide pollution belowthe quality in the region, including adoption of local innovative programs. annual standard. The commenter urges that**a~emative** and non-air-polluting energy sources be promoted by measures like Green Bulldings and LED lighting. 9 The draft SIP does not adequately oulline a process that w8 assure Cny ofAlexandria, VDEQ, MWAOC and Ihe states disagree; they believe that the programs outlined in the allainrnent plan are sufficient to that the OC-MD-VA Region meets the NAOS standard for PM2.5. RogerWaud OCOOE accompfish the SIP goal. The main purpose of this allainment plan continues to be demonstrating compliance wth the Howwilt existing permit programs be specifically implemented, or 1997 standards of 15.0 uglm' annually and 65 uglm' daily. FRM data show that the region has already attained the enhanced, in regards to PM,.,. 1997 standards of 15.0 uglm' on an annual average and 65 uglm'on a daily average. These accomplishments may be attributedto many of the control programs implemented in previous allainmenl plans for ozone. Additional federal. state, and supplementat conlrol programs. as outlined in the draft attainment plan, wI continue to reduce precursor and direct emissions of PM,•. MWAOC and the states agree that ij is important to be mindful of the 2006 PM" NMOS standard on a regional basis. Section 8,2 ofthe drafl attainment plan discusses the changes made to the majorstationary source permitting program in regards to PM'3. Section 8.4 notes the inlention by the state agencies to adopt further PM" nonattainment permitting requirements, induding requirements for precursor emissions, controls, and offsels, when these regulations are finalized by EPA. 10 The attainment plan should conlain more rigorous monitoring, Alexandria, VDEQ, MWAQC and the states disagree Wth the comment that current permitting. enforcement, and monitoring program permilling, and enforcemenl programs. Rigorous monitoring Efizabeth Chimento OCOOE requirements are lax and thatthere is an absence of a compliance and enforcement apparatus. Facilities thatlrigger programs and more severe limitations are necessary due to model major new source review permitting. either as new ormodified sources, must install technology deemed to meet lowest uncertainty. Lax permitting, monitoring. and compliance programs achievable emission rates (LAER). Monitoring and enforcement programs in the Northern Virginia Regional Office allow increases of emissions over this allainmenl plan's emissions (NRO), VDEQ, MOE, and OCOOE are slrong. inwntories and caps. 11 VDEO's proposed permit for PRGS is conlradictory to SIP goals. City ofAlexandria VDEQ, MWAOC and the states disagree. The main purpose 01 this attainmenl plan continues to be demonstrating compliance The inventory used in the attainment plan regional modeling exercise OCOOE wnh the 1997 standards of 15.0 uglm' annually and 65 uglm'daily. FRM data show that the region has already attained is less than proposed permit limits and therefore underestimates the 1997 standards of 15.0 uglm' on an annual average and 65 Uglm' on a daily average. emisSlons..:_



### MWAQC PM2 5 

### SIP Appendix K Attachment I - Page Number: 3 March 7. 2008

## i; E.c Comment Commenter Recipient Response EE " ::J oz The proposed PRGS permit reduces emissions from the baseline yearforthis facilty. MWAOC and the states believe that the proposed permit 1MB improve air qualty and is not contrary to the goals ofthe PM,.• attainment ptan. In addition, the attainment plan requires thai PRGS perform an ambient air quaUty analysis when the methodology lor such an analysis is finalzed. The results ofthis study may showthat additional controls on PRGS are needed to ensure the PM25 NAAOS is met. MWAOC and the states do not support the approach ofsetting projection year emission inventOries equal to permitted limits or potential to emit. Regional modeling inventories are based on actual emissions and projected emissions. Projected emissions are rarely, if ever, as high as the potential to emit of a facility. Projected emissions are generally extrapolated using a base year's actual emissions inventory and applying a conservalive growth factor, as required by EPA. In some instances, projected emissions are adjusted based on conlrol estimates. Ho_ver, projected emissions are almost never based on polentialto emil ofa facility. MWAOC and the states believe that the 2009 projection year inventory is quite conservative, 12 The attainment plan does nol discuss additional RACTIRACM in City ofAlexandria VOEQ, 40 CFR 51

.. 1010, ..nich delneates requirements for reasonably available control measures (RACM) and reasonably enough detail. DCOOE available control technology (RACT), predicates the implementation ofa suite ofmeasures on whethenhose measures can collectively advance the attainment dale ofa nonattainment area by one year. Since the metropolitan Washington area is ctlfTently attaining the PMu NMOS, based on FRM data for 2003-2005 and 2004-2006, it is not possible tor any suite of measures to advance attainment. This explanation is provided in section 8.3 ofthe draft attainment plan

_ 13 U.S. EPA's Clean AifFine PaJticulate Implementation Rule suggests City ofAlexandria VDEQ, MWAQC and the slates disagree with the comment. Thejustificationfor examining monitoring and opacity standards is the use ofmore stringenl monitoring and opacity standards. DCDOE discussed in EPA's Clean Air Fine Particulate Implementation Rule (72 FR 20586. April 25. 2007) in the RACTIRACM Virginia'S current opacily standard of 20% allows PM,.• emission requirements. RACTIRACM requirements are predicated on advancing the attainment date, ..nich is not possible for the increases 1Mth0ut adequate review. Opacity limitations should be metropolitan Washington area. Unless a lacility undergoes a major modificalion as pari 01 the new source review major strengthened to no more than 10%. permit1ing process, in which case LAER must be appled, or undergoes a minor modification in which case state Best Available Control Technology (BACT) must be applied, there currently is no basisfor revielMng source-specific opacity standards applied to ma'or stationary sources. 14 Both proactive and prescriptive measures to reduce fine particle AQPAC MWAQC MWAQC and the states agree that additional measures need to be implemented to continue to improve air quatity in the pollution are 01 significant interest to the public and

_ encourage region, especially considering the pending new lo_rdaily PM,.• standard. States and local govemments continue to their development and implementation. Pushing forward on these identify and develop new policies and programs to reduce emissions in the ravion and in areas upwind of the region, initiatives now, especially since some require medium- to long-term planning, is essential in light ofthe reduction of the daity standard to 35uwm' , 15 Education of the public on the heaHh related issues offine particles AOPAC MWAQC MWAQC and the states agree that pubUc education programs are an imporlant pari of the region's strategy to protect should also be intenSified, since it WU facilitate luture voluntary or human health and improve airquality. regulatory reductions for both fine particles as _II as expected requirements to reduce other polutants with similar sources. such as greenhouse gases. Attainment Modeling 16 CMAQ generally over-predicts during IMnter months and under- City ofAlexandria VDEQ, The Model Performance Evaluation (MPE) included in the metropolitan Wssihington attainment plan was developed

_._--_. predicts durina

.. summerrnonths. Statisticalmetrics Sych.as tractional ,

. - c.JJ.CPOE

.**~sed** <lIl.inputfrom severalIl!jjional planning**group~uchas** th"Mkl-AtlanticlNortheastVisibility Union (MANE-V\)},

MWAQC PMV SIP Appendix K Attachment I

- Page Number: 4 March 7. 2008c**~** 

# I**~1l** Comment Commenter Recipient Response 

## 8§ uz ! error and bias do not provide assurance lI1at lfle model predictions the Ozone Transport Commission (OTC) and lfle Association for Southeastern Integrated Planning (ASIP). SPecif.caiiYl meet lIle modeling performance goals on either a 24-hour oran all elements of the modeling platform, including II1e emissions, meteorology, and air qualily model, have undergone I annual baSis. There is nO observed error in model performance on exiensiw evaluation. the end model result in the target year of2010. The design value cak.uiations should include columns of maximum predicted values The resuHs of the MPE for the metropolitan Washington area for PM".and its individual species indicate that the CMAO thai reftecl the model's ....,rst-case performance for this modeling model performance for surface PM,. is good, with acceptable bias and error. The MPE was consistent with EPA domain. The analysis relies too heavily on II1e trend in Observed guidance and includes II1e proper statistical performance metrics. PM,., levels. MWAOC and II1e states believe the issues identified by the commenter are not regulatory requirements and are not appropliate lorinclusion in the attainment demonstration since attainment tests are based on the application of relalive response factors. 17 The analysis relies too heavily on the trend in observed PM15 ievels, City ofAlexandria VOEO. MWAOC and the states recognize that model resutts and projections wil continue to haw associated uncertainty. The OCOOE attainment demonstration that EPA recommends recognizes this by including modeling plus other supplemental analyses such as air qua.ty trends to determine whether all avalable evidence supports a conclusion that a proposed emission reduction plan will suffice to meet the NMOS. 18 VOEQ should not rely on PM,a as a surrogate for PM,.• in II1e City ofAlexandria VOEO, MWAOC and II1e States not believe that the PM,., attainment plan is an appropriate arena in which to wscuss federarpermitting process for PRGS. OCDOE permitting guidance. Such permitting concerns are more appropriately addressed through the many significant public participation opportunities afforded the public during the permitting process. 19 The SIP does not address the reduced operational loads of PRGS City ofAlexandria VOEO, The goal ofthe attainment plan is to demonstrate compliance with the 1997**PM,~** NMOS by 2009 on a reg.onal basis. that were important events in relation to the downward 24-hour OCOOE design level trends between 200244 and 2003-05. Chapter 9 MWAOC and the Stales do nol agree that**deta~ed** discussions of every facility's operational changes between 2002 and should include a thorough diSCUSSIOn, along with 8 timeline that 2009 are necessary. matches II1e implementation of the regional programs with the FRM monitOring resuHs and include the effects of various aclions concerning PRGS on the decline in regional values.

.,,- local Hotspots 20 Local hotspots should be addressed in the SIP. City of Alexandria, VDEO, EPA does not define a hotspot in the implementation rule. The current EPA guidance for regional modeling fo support Julie Crenshaw OCOOE, attainment plans notes that local area analyses are required for areas within a region that show elevated monitored PM" Van Fleet AOPAC, MWAOC concentrations at monitors within the federal reference monitoring networl< when compared to data from other federal RogerWaud, reference monitors in the region. There is no identified gradient in PM concentrations in the FRM nelworl< in the Elizabeth Chimento metrOpOlitan Washington region. Therefore, by EPA's definition, there is no requirement to conduct a local area analysis. MWAOC and lIle states are aware ofhighly conseMltive micro-scale modeUng thaI indicates the pOssibility of a "hotspot" in the City ofAlexandria even though current data from the**mon~ors** located In the modeled area show that concentrations Bre weD beneath the NMOS. Additionally. FRM monlloling data al the monitoring station in Arlington show compliance with the NMOS. Regardless, the SIP does include requirements for further actions to address the concerns regarding emissions from PRGS through additional analyses, when methodologies become available. a. required by Sadion 9.4.3.

MWAQC PM 25 SIP Appendix K Attachment I

- Page Number: 5 March 7, 2008

### "**~** 

## Ell Comment Commenter Recipient Response EE 0:> uz 21 The SIP should include either an Unmonitored Area Analysis or a City of Alexandria. VDEO, MWAOC and the states believe that the most appropliate means to address the coocems raise<! about the emissions local Area Analysisfor the Potomac River Generating Station and Julie Crenshaw OCOOE, from PRGS on the surrounding community is through the Virginia permitting process,but the SIP does conlain a other large poinl sources. The regional monitoring netwo"" is not Van Fleel. AOPAC. MWAOC requiremen1 for Mirant to prepare and submit a modeling analysis once federal guidance is available. robust enough 10 detect exceedances ofthe NAAOS in the Cityof RogerWaud. Alexandria that are caused by the Mirant facility. modeling tools are**E~zabeth** VDEO is currenlly in the process of conducting the Unmodeled Area Analysis (UAA) for the metropOOtan Washington avaiable, and the SIP is the appropriate means to address the Chimento. Sierra area, VOEO is also part ofthe test group for the recently release<! bela version of EPA's "Model Attainment Test situation. Club. Flint Webb Software (MATS)" which is the tool required to conduct the UAA. Unfortunately. this tool is hmited and does not have the spalialfield feature necessslY to complete the UAA. EPA expects that this component wiM be added in the next version of MATS andVDEQ wiD complete the analysis upon release ofthe updated software. 22 The requirement for a local Area Analysis for the Potomac River Mirant Potomac VDEQ, MWAQC and the stales disagree. The Commonwealth 01 Virginia hasthe authorityto require analysls 01 the emissions Generating Station should be removed from the SIP. River llC MOE, from the PRGS to determine whether the facility causes or contributes to exceedances oflhe NAAOS in the City 01 OCOOE Alexandria or elsewhere within the nonattainment area. The PM SIP isa regional document to address the regional PM health concerns within an EPAdeSignated nonattainment area. The SIP therefore provides a nonatlainment control approach to health concerns that arejOintly shared by aljurisdictions in the designated metropolitan Washington area. 23 An FRM monitor should be sited in the City of Alexandria and at other Julie Crenshaw VDEQ, Fora number of reasons, il is impractical to locate PM"" FRMs nearovelY source, or even evelY major point source, of locations that have large PM" sources. Van Fleet. AQPAC. OCOOE, PM,.• emissions in the metropolitan Washington area. However, the Commonwealth ofVirginia is considering siting a Rogerwaud MWAQC new FRM monilor in the City ofAlexandria. Two special purpose monitors located near the PRGS are providing data on the impacts of the lacilityon air quafily in the City. These data wi. continue to be coMecled and analyzed.
24 The language in Section 9.4.3 that requires an ambient air quality City ofAlexandlia VDEQ. MWAQC and the states do not believe the language suggested by the commenler is appropriate. It is not ceriain that analysis is deficient since it fails to insure that the analysis wil be OCOOE Gaussian dispersion modeOng wiD be a requirement of PM,.!! ambient airquality analyses. EPA has not yet published done in a timely manner. It also suggests that methodologyto modeling guidance for PM,. pollution. Use ofpublished guidance for other poUutants. such as SO" is not prudent given conduct such an analysis is not**ava~able** at the present time, which that the highly complex nature of PM,schemistlY may not make the use of guidance lor other pollutants applicable. If ;s contralY to existing EPA guidance. The language should be Gaussian dispersion modeling is eventually required. no federal guidance currenlly exists explaining the application to revised to read: PM,.. of this technique. which is muh"faceted and highly compticated. Using an available Gaussian dispersion model. such as AEROMOD, The language included in Section 9.4.3 stales that the timeline for submitting the analysis will be determined byVDEQ lor sta&onary soun:es. which has been approvedby USEPA to management. This language was included to accountforthe lactthai the requirements of the ambienl air quakly modelprimaryPM" impacts. VOEQ shaH conduct an ambientair methodology are not known so thai a reasonable timeframe cannot currenlly be fixed. HOlMlver. VOEQ can require that quality analysis ofthe emissions ofPM,sfrom the Mirant Potomac PRGS**subm~** a prolocol once the final methodologies are approved by the SAPCS within a ceriain lime frame. for RiverPower Generating facility VDEQ shallcomplete this analysis instance 60 days. Section 9.4.3 has been updated to rellect this change and now reads: WIthin 120 days ofadoption ofthe SIPby MWAQC. Based on a Schedule andprotocol to be establishedby VDEQ aller US EPA promulgates fmal rules for PM" analySiS. or US EPA promulgates revised implementation guidance orpolicy for PM2.5 analYSIS. or VDEQ establishes a more appropriate implementation methodology for PM,s. Mirant Potomac RiverPowerStation shall conductan ambient air quality analysis for the emissions ofPM 15 from the facility. No laterthan 60 days allerapproval ofthe Implementation method%iiybythe Virginia State AirPollution Control Board. Mirant Potomac RiverPower StatIOn shaHproVide to

MWAQC 

### Plvh5 SIP Appendix K Attachment I - Page Number: 6 March 7, 2008

# -**c~** 

## L!: Comment Commentsr Recipient Response 

### ee o " oz VDEQ a detailedprotocolOUUining0011\1 the facilitywill implement the approvedmethodologies VDEQ Will make thIS document available to the public bypublishing this protocolon the VDEQ website

Technical Corrections 25 The SIP should be rellised to include reference to the 24-hour PM,.• Marilyn Powers, 

### voea MWAOC and the slates agree. The SIP was revised to incorporate the commente(s suggestion. standard. U.S. EPA Reaion III 26 The SIP should be revised to rellect the fact that Virginia's rule Marilyn Powers, 

### voeo MWAQC and the slates agree. The SIP was revised to incorporate the commente(s suggestions. capping emissionsfrom pomr plants in the region is a state-only U,S. EPA Region III requirement and is not part of the CAiR rule. The commenter also suaaested a minor editorial chanae for Section 9.3.1. 27 The commenter requests that the following revislans be incorporated Thomas Ballou, MWAQC MWAQC and the states agree. The SIP was revised to incorporate the commente(s suggestions. into the SIP documentfor the ninejurisdictions in Northem Virginia VOEQ that are II part of the Washington, DC-MD-VA PM2.5 nonattainment area:
1. Forthe following source categories, update emissions, associated documentation and NIF 3.0 emission files in the BY 2002 emission inventory document and its appendices (Appendix B of SIP) 10 rellect Ihe BY 2002 emission estimates for these categories: 1) The emissions for the 9 Northem Virginia jurisdictions coded under SCC 2810015000 shouid be moved to SCC 2810014000; 2) The emissionsfor the 9 Northem Virginiajurisdictions coded under SCC 2285002005 should be moved to SCC 2285002006; 3) Zero out the emissions for SCC 2610000500, Open Burning-Land Clearing for all 9 Northem Virginia jurisdictions. The emissions for this SCC that mre included in lhe SIP inventory mre originally developed by the EPA and added to the National Emission Inventory as part of EPA's augmentation process. Since the SIP inventory was compiled, m have discovered that EPA has reviemd these emissions and for jurisdictions that mre greater than 80% urban, those emissions were zero'ed out otthe EPA 2002 National Emission Inventory. Therefore. m are requesting that MWCOG remove those corresponding emissions from the PM2.5 SIP.
2. Changes in the BY 2002 emission invenlory made above will change the future year Inventories and associated analyses and documentation, Therefore, also update future vear emissions and

MWAQC PM2.5 SIP Appendix K Attachment I

- Page Number: 7 March 7.2008**~** ; :ti E.o Comment Commenler Recipient Response E E o '" uz associated analyses and documentation in the main SIP document and related appendices.
The recommended changes do not change the overaM SIP conclusions.

28 The commenter requests additional deta.l on an appropriate method Charley Baummer, VDEQ Through the MWAQC process an airports subcommittee was formed and discussions were held regarding the to determine whether and howairport construction emissions are Metropolitan developmentof specific airport emission inventoryfine items for regional airports. This emissions information would be renected in the SIP. Washington Airports the metric to examine an the emissions related to airport operahons (construction, airptanes. operation emissions. etc.). Authority Stakeholders declined the offer to pursue airport specific emission inventory tine items. Details of what can be done to estimate the construction emissions attributableto airport construction in the StP can be determined at the time the information is needed. 29 The commenter provided a list ofvoluntary local air quafity City ofAlexandria VDEQ MWAQC and the states support inclusion 01 toeal voluntary initiatives in the SIP. The SIP was revised to include the improvement initiatives and asked that they be included in the SIP, measures idenlilied by the commenter. for no emisston reduction credit. 30 The Figure (Figure 2-5) does not include data for March through Sepl Flint Webb VDEQ Included data in the graphthrough December 2005 as requested and also to be consistent with other graphs in Chapter 05. 2. 31 The texl (in Section 2.2 4) doesn't appearto be supported by the Flint Webb VDEQ Updated Figure 2-6 to replace ammonium ion data with ammonium nitrate and ammonium sulfate and sedion 2.2 4) to figure. The figure is of ammonium ion concentrations but the texl provide information on ammonium nitrate and ammonium sulfate as requested. discusses ammonium nitrates and ammonium sulfates. Pernaps there should be two plots, one ofammonium sulfates and onefor ammonium nitrates. 32 The Figure The terms on the figure need to be explained (I.e. what is Flint Webb VDEQ Figure 2·10 tide was updated to better elCplain the content and terms ofthe figure as requested. ·Passive"). What are the units I presume it is % by mass but it is not stated. 33 Section 3.2.2
- Need to darify the difference between area "non- Flint Webb VDEQ The difference between area "non-stationary" sources and mobile sources was darified by providing a lew examples. stationary" sources and mobile sources. Pernaps examples like mobile genera"'rswhich are stationary when operated but could operated anywhere in the region. 34 Section 3.2.2

- "or county-equivalent" should probably be defined FlintWebb VDEQ Since MWAQC area inventory is calculated at county level, the term 'county-equivalent" is not relevant inthe discussion earlier on inthe document or perhaps footnoted. in this paragraph and therefore is being deleted. 35 Section 3.2.2·The distinctions between Area and Mobile sources Flint Webb VDEQ A line has been added in the 1 paragraph ofthe Section 3.2.3 (Onroad mobile sources) to der_ what COf'Istitute /llObile

MWAQC PMz5 SIP Appendix K Attachment I

- Page Number: 8 March 7. 2008

### ,-**~** ; E", Comment Commenter Recipient Response E E o " uz need to be clarified. sources. Area source section (Section 3.2.2) prolrides details about area sources. Discussions in these two sections make distinctions between area and mobile sources very clear. 36 This figure (figure 2-10) stil either needs much more explanation or Flinl Webb VDEO The reason whVammonia is not considered a significant precursor is explained in detail in various places in the SIP Ihe whofe sec:lion should be deleted. The figure shows that including chapter 2 (section 2.8) immediately after Figure 2-10. ammoniated compounds account for 65% of the SANDIMCH material and yet we are not considering ammonia emissions. The minor modification to the text from the prelrious version is an improvement but does not flO far enough. 37 Figure 2-11 y-alCis should show ajog indicating that the x-axis is not FtiotWebb VDEQ The range of !he Vaxis in Figure 2-11 was defined from 14.0 to 17.5 in order 10 clearly visualize a dedining design value at zero or Ihe x-alCis should go dov.n 10 zero. The figure makes It trend Hne. Extending lhe y alCis all the way to 0.0 instead of 14.0YAU make the Irend tine look almost nal. Also. dala are lOOk li4I:e the annual concentration is almost O. Alternatively there labeled for design values for different years and the annual PM2..5 standard line in the graph. which make the graph qude should be a zig-zag line indicating thallhe axis is not at zero. clear. 38 Section 3.2.4

- Non-road airport veIlides need 10 be mentioned in !he Flint Webb VDEO All nonroad vehicles are part of nonroad inventory and sO must slay in nonroad section itself and should not go to area Area source section (3.2.2). source section. 39 Section 4.1.1.2

- Since the Area soun:es make up a large portion of Flint Webb VDEO Growth surrogates for differenl area and nonroad source categories were decided in consullation wilh the Slate air the invenlory il is important that the growth factors are correct. II agency slaffand lhe Emissions Inventory Sub-Committee. Though the surrogales for the categories mentioned in the would be good to compare some of Ihe !actors YAlh historical growth commenl above may not completely provide \rue picture ofgrowth for those calegories. they are certainly Ihe most factors. SpeciIicaIly a comparison YAth historical growth for the appropriale surrogate available 10 us. fofloYAng is requesled; -Residential Fuel Combustion
- Has there been an increase in natural Also. the commenter now should not be concerned aboul50% growth for "Open Burning" as these emissions are not gas usage that may off-sellhe household increases? removed from Virginia inventory as part of the public commenl made by VDEQ. -Open Buming
- Using population as a growth factor means Ihal II would increase by 50% for Loudon County. -Municipal landfills and Incineration· much ofthe trash in the region is disposed of in municipal waste incinerators. Unless !he municipal waste incinerators are operating at capacity it is questionable whether a zero growth factor is appropriate for incinerators and ifthey are at full capacity then the municipailandfiU emissions may grow faster than simply the rate of population groYAh. -Fugitive Dust
- Using VMT as the growth factor implies that all fugitive dist emissions are associated YAth on-road vehicles. Isn'l much of ilassociated YAth construction activity? Notes • For additional detailed response 10 comments, please See Appendix K Anachment2.

MWAQC PM25 SIP Appendix K Attachment I

- Page Number: 9 March 7, 2008