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 of this letter is to submit copies of Maryland's Fine Particle (PM2s) State 

Implementation Plan (SIP #08-06) and 2002 Base Year Inventory for the Metropolitan 

Washington, DC-MD-V A Nonattainment area. This SIP submission consists of a 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-VA Nonattainment 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 on January 30, 2008. 

All required administrative procedures were followed throughout the hearing process. If you 

have any questions concerning this submission, please feel free to call George (Tad) Aburn, Jr., 

Director of the Air and Radiation Management Administration at (410) 537-3255. 

Sincerely, I JL ~ilson Secretary 

Enclosures 

cc: Judy Katz, USEP A Region III 

George (Tad) Aburn, Jr., Director, ARMA, MDE 

~ Recycled Paper www.mde.state.md.us TTY Users 1-800-735-2258 

Via Maryland 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 

Maryland State Implementation Plan 

(PM2.sSIP) 

State Implementation Plan for Fine Particle (PM2.S) 

Standard and 2002 Base Year Inventory for the 

Washington DC-MD-VA Nonattainment Area 

SIP Number: 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 of the 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 30,20086 pm 

MNCPPC 18t Floor Auditorium 

8787 Georgia Avenue, Silver Spring, MD 

District of Columbia 

February 11, 2008 6 pm 

District Department of the Environment 

51 N Street, NW, 6th floor, Washington, DC 

PUBLIC COMMENT DEADLINES AND ADDRESSES 

Email: mwaqcpubliccomment@mwcog.org 

Cecily Beall 

District Dept. of the Environment 

Air Quality Division 

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 Quality Planning Program 

Maryland Department of the Environment 

1800 Washington Boulevard 

Baltimore, Maryland 21237 

bhug@mde.state.md.us 
Maryland Department of the Environment 

Notice of Public Hearing on Air Quality Plan 

The Maryland Department of the 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-VA Nonattainment Area. The Washington DC-MD-VA Nonattainment Area includes 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) 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 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 N onattainment 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 of comments received, the 

plan will be finalized and submitted to the United State Environmental·Protection Agency. 

The SIP document has been made available on the Maryland Department of the Environment's website at 

http://www.mde.state.md.us/Programs/AirPrograms/air planning/index. asp titled the "Plan to 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 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 
Comments 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 the hearing by notifying MDE five 

(5) business days before the hearing. TTY via Maryland Relay for the hearing impaired is (410) 537-

4396. 

For more information contact Randall Carroll, Air Quality Planner, at (410) 537-3252 (Toll free in 

Maryland call (800) 633-6101 ext. 3252) or RCarroll@mde.state.md.us. 
( 

PROOF OF PUBLICATION 

I, Michael E. Phelps, Publisher of The 

Washington Examiner, (Maryland 

Edition) a newspaper in the area of 

Maryland, published in the English 

language and located in the Maryland 

area, and entered in a newspaper of 

record according to the Laws and 

Regulations of the United States of 

America for 52 successive Weeks or 

more prior to the issue of December 27, 

2007, certify that the notice of: 

Air Quality Plan 

for Maryland Department of 

Environment Fiscal Services Division. 

Attached hereto has been published on 

December 27, 2007. 

Michael E. Phelps 

27 u. of December 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 of PubUc Hearl 

The Maryland Department of the Environment (MOE) "" . Plan (Sun addressing the Annual Fine Particle (PM 2.5) S 

ment Area. The Wasliington DC-MD·VA Nonattainment 

Charles, Frederick. Montgomery. and Prince Geor~s. n 

Jan~30,2008 at _PM at the ~and National C 

dltorlam, 8787 GeoJ'lllaAvenue. SIhir Spring. Maryl 

The Public Hearing will be held as required by federalla .. 51.102). 

The proposed I'lan Is tided the Star,lmplementaNon PIa 

2002 Base Yearlnuenrory for rhB Washington OC-MD-VA j 

ventories, ~ measures, an attaburient demonstrat!. 

taIns the base year 2002 air pollutant emissions inventor 

basis for an p~ aaivitles related to the Annual Firu 

NonattaJnm:ent Area. 

On December 12, 2007. the MetropolitanWasbJngtonAb plan for release for pubUc review and comment After co 

ilalized and submitted to the United State Environmenta 

The SIP document baa been made available on the Maryi 

~ ~ ·"=':~L::Yfb.~~=!!9=&~ temet access to view document. 

1; Copies oftbe document~,~ be viewed at the folJowing Ie 

l; . I. M!U}'land Dep ent of the Environment OOl( ~ Adniinistradon, 800 Washington Boulevard. Su , Randall CarroD or Brian Hug. 

2. Metropolitan Washington Council ofGovemme 

WashJhgton, DC 200(12 • Contact: Jeffrey King 

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 Center Drive. Suite 300, Springfield. Virginia ~ 22151 • Main: 103-839-8320 .~ Fax: 103-138-0619 

'Yvww.dcexaminer.com 
---!~------------------------------------------------~ 

Maryland Department of the Environment 

Notice of Public Hearing on AIr' Quality Plan 

The Maryland Department of the 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 DC-MD-VA Nonattainment Area. The Washington DC-MD-VA Nonattainment Area includes the following Maryland counties: 

Charles, Frederick. Montgomery, and Prince George's. The Hearing will be held on: 

January 30,2008 at ti:OD 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) for Annual Fine Particle (PM 2.5) Standard and 

2002 Base Year Inventory for the WashingtonDC-MD- VA NonattainmentArea. The plan contains emission inventories, control measures, an attainment demonstration and motor vehicle emission budgets. This plan con- tains the base year 2002 air l?ollutant emissions inventory and 2009 projected inventory. which serves as the 

basis for all plarming 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 

'llan for release for public review and comment. After consideration of comments received, the plan will be filalized and submitted to the United State Environmental Protection Agency. 

The SIP document has been made available on the Maryland Department of the Environment's website at 

http;/ /www.mde.state.md.us/Pro~s/AirPr~s/air planning/index, asp titled the "Plan to Improve Air 

QUality in the Washington. DC-M -VA Region" ote: 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 

Comments 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 oJ business January 30, 2008. 

A hearing impaired person may request that an interpreter be present at the hearing by notifying MDE five (5) 

business days before the hearing. TIY via Maryland Relay for the hearing impaired is (410) 537-4396. 

For more information contact Randall Carroll, Air Quality Plarmer. at (410) 537-3252 (Toll free in Maryland call 

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

December 27. 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 Post Media express 

EI Tiempo latino I 

Shan'nel McCanneli Slate 

Account Executive 

BUSiness and Flanancial Opportunities 

;~o~~~~~~;OSf ta1001l56

0

215fh Streel NW I Washington, ex: 20071 

b .' . 71150 exl457a71 f 202334.6724 e uSlnessopps@Washpost.com 
Ad # 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."'.en t s rece i 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 1010046059 
Ad # 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 1010046059 
Ad # 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 - Press Release Page I of2 

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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 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 COl 

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

greater risk from this type of pollution. 

Levels of fine 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 of fine 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 of Columbia, 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 of fine 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 of fine 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 of the 3~-day public comment period around 

December 28, and it will end with public hearings in the region the week of January 

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 - Homepage I Search 

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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 

January 2008 - 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 of the Environment - Calendar of Events Page 1 of2 

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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 Meeting for.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 Permit forSynagro 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 Permit to Construct Inf()rmational Meeting for Dominion Cove Point 

for 2 Boilers 

Tuesday, February 5, 2008 

Public Hearing - Renewal of State DischarQe...PerooLt foube Sudlersville 

wastewater Treatment .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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[ 

C 

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D 

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. Calendar of Evenfs 

@J. . ~ [2l [i} (§) ~ ...• . ----- - . -- --. 

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 

Maryland Department of the Environment I ©Copyright 2002-2008 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 
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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 of the 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 Request for 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 of the 

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 I MDE Calendar I Environmental Programs I Permits I Text Only __ 

Home> Environmental Programs> Air Programs> Air Quality Planning '1 

AirQuality • 

M OJ] ito ring 

Ai rJlI.Lality 

~n~ 

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AlrQUiJlID 

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.... Air Quality Presentations 

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 AirProgramsl air 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 Ki ng 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 I MDE Calendar I Environmental Programs I Permits I Text Only II 

About MDE 

Air: 

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C.iti~~.!1s1nfo 

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Home> Meetings & Hear 

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. 

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20 

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21 

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Site Index Privacy Notice Accessibility 

1800 Washington Blvd, Baltimore, MD 21230 

Tel:{410) 537-3000 Toll Free:{800) 633-6101 

Maryland Department of the 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 
Opening Remarks 

Public Hearing on State Implementation Plan (SIP) 

For Annual Fine Particle PM (2.5) Standard 

Date: January 30, 2008 

Randall Carroll, Hearing Officer 

Maryland Department of the Environment, James Wilkinson 

If the court reporter would turn on the equipment, we will begin. Good Evening. 

On behalf of the Maryland Department of the Environment, Air and Radiation 

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 CFR Parts 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 of this public hearing has appeared in the Washington Post Newspaper on 

December 27,2007 and the Washington Examiner Newspaper on December 27, 

2007. 

Notice was also posted on the Maryland Department of the Environment web site 

commencing on December 27,2007 and the Metropolitan Washington Council of 

Governments website on December 12, 2007. 
My name 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, if you 

haven't already done so. This will help us to keep an accurate record of the people 

who participate in our proceedings here today. Also, a full copy of the 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. This plan 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 of the 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 or government 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. Hearing procedure does not call for question 

and answer sessions. Statements recorded at this hearing event will be answered in 

writing and published with the fmal State Implementation Plan document. Are 

there any procedural questions? 

Once all questions have been taken -- if there are any -- you are ready to 

begin. 

If the court reporter would begin we will go on record to receive comment. 

Mr. James Wilkinson will proceed with the Department's statement. Again, there 

are copies on the back table you may use to read along. 

3 
(While Jim reads his statement you get up and walk to the back and pick up 

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 thank him and look to call 

on any elected officials who wanted to make a statement first. If there 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? 

(If no one wants to make statement say:) 

No one has indicated that they wish to make a statement, is there anyone 

who would now like to make a statement, even if they did not indicate so on the 

sign-in sheets. 

(After all statements have been presented, say) 

Let the record reflect that a statement has been taken from all who wish to 

make one. This will conclude this public hearing. Let the record reflect 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 of these proceedings 

on January 30, 2008. 

PUBLIC HEARING 

WHAT TO SAY IF NOBODY SHOWS FOR THE HEARING 

• WAIT AT LEAST 30 MINUTES BEFORE YOU DO ANYTHING !II 

IF THE COURT REPORTER WOULD 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 comment period for the document of record 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 
Statement of the Air and Radiation Management Administration 

Maryland Department of the Environment 

For the Public Hearing Concerning 

State Implementation Plan (SIP) for Annual Fine Particle (PM2.S) Standard and 2002 Base Year 

Inventory for the Washington DC-MD-VA Nonattainment Area 

Held on January 30, 2008 

Good Afternoon. My name is James Wilkinson. I am a Planner in the Air Quality Planning Division, Air 

Quality Planning Program of the Air & Radiatio.n Management Administration, Maryland Department of 

Environment. 

This public hearing is related to the air quality plan titled the State Implementation Plan for the Annual 

Fine Particle Standard and 2002 Base Year Inventory for the Washington DC-MD-V A Attainment Area. 

This public hearing is being held pursuant to federal law found at 42 U. S. C. § 7410(a) and 40 CFR Parts 

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 of this public hearing appeared in the: 

• Washington Post on December 27, 2007 

• The Examiner Newspaper published on December 27,2007 

• Maryland Department of the Environment website on December 27,2007 

• Metropolitan Washington Council of Governments website on December 12,2007 

Copies of each of the public hearing notices and the Proposed State Implementation Plan for the Annual 

Fine Particle Standard and 2002 Base Year Inventory for the Washington DC-MD-V A Attainment Area 

will be part of the formal hearing record. 

Access to the proposed document was made available via the web sites of both the Maryland Department of 

the Environment and the Metropolitan Washington Council of Governments. Hard copies were also 

available at the Maryland Department ofthe Environment and the Metropolitan Washington Council of 

Governments. 

The purpose of this hearing is to provide the public with an opportunity to formally comment on the 

proposed document. 

Summary of Proposed State Implementation Plan for the Annual Fine Particle Standard 

The Clean Air Act Amendments of 1990 represent an unprecedented commitment to protecting public 

health and the environment. A high level of fine particles is a health problem. Fine particle pollution is a 

mixture of microscopic solids and liquid droplets suspended in the 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 

1 
adults and children are at greater risk from this type of pollution. It is especially harmful for those with 

respiratory problems such as allergies, asthma, bronchitis and emphysema; and greater susceptibility to 

respiratory infection. 

On March 29, 2007 EPA finalized the Clean Air Fine Particle hnplementation Rule defining requirements 

for state plans to meet the 1997 National Air Quality Standards for fine particle pollution. Monitored 

levels of fine particle pollution have been declining in the Washington DC region since 2005. Under the 

proposed regional 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 of MD-V ADC have prepared a plan to further reduce level of fine particles by 2009. Through the purchase of wind 

power energy, green buildings, improved energy efficiency and increasing the tree canopy in the region, 

local governments are helping reduce air pollution. 

EP A designated the metropolitan Washington region as a nonattainment area for annual fine particulate 

matter in January 2005. The region has demonstrated compliance with the annual PM2.5 standard for the 

last several years. The geographic scope ofthe region includes several Maryland Counties including 

Montgomery, Prince George's, Frederick, and Charles County. 

This document, the State hnplementation Plan for the Annual Fine Particle Standard and 2002 Base Year 

Inventory for the Washington DC-MD-VA Nonattainment Area is a plan to improve air quality in the 

Washington region to meet the National Annual Fine Particle Standard. The Plan consists of Base Year 

inventories for 2002, projection inventories for 2009, an attainment plan, a demonstration of reasonable 

available control measures, motor vehicles emission budgets for 2009 and 2010, an attainment 

demonstration, and contingency plans for attainment. 

The plan has been prepared by the Metropolitan Washington Air Quality Committee to comply with the 

Clean Air Act Amendments of 1990 and with EPA requirements for the Washington region as stated in 

EPA's 2005 designation of the Washington region and EPA's Clean Air Fine Particle Implementation 

Rule. 

CONSIDERATION OF COMMENTS 

The Department will consider all pertinent comments, and revise the proposed plan if necessary, before 

making a final decision to adopt the plan and submit it to the U.S. Environmental Protection Agency for 

approval as a Maryland State hnplementation Plan. Written comments may be presented at this hearing 

but cannot be accepted if not presented before the close of the hearing. The 30-day public comment period 

that began on December 27, 2007 for receipt of all comments to the plan will close at the end of this 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 . ~"~r.sf·J.1 .... p Lc.J ~ lO 
Martin 0 'MallIfY 

Governor 

Mary/and Department of Planning 

Anlho'!Y G. Brown 

l.J. Governor 

Mr. Randall Carroll 

January 17,2008 

Air Quality Planner, Air and Radiation Management Administration 

Maryland Department of the Environment 

1800 Washington Boulevard 

Baltimore, MD 21230 

STATE CLEARINGHOUSE REVIEW PROCESS 

State Application Identifier: MD10071217-1133 

Richard Eberhart Hall 

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 of Maryland, and Virginia; and the District of Columbia 

Clearinghouse Contact: Bob Rosenbush 

Dear Mr. Carroll: 

Thank you for submitting your project for intergovernmental review. Participation in the Maryland Intergovernmental Review and 

Coordination (MIRC) process helps ensure project consistency with plans, programs, and objectives of State agencies and local 

governments. 

Notice of your application is being provided to State and local public officials through the Intergovernmental Monitor, 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 of Maryland Regulations (COMAR 14.24.04) and this concludes 

the review process for the above referenced project. If you need assistance or have questions, contact the State Clearinghouse staff 

person noted above at 410-767-4490 or through e-mail atbrosenbush@mdp.state.md.us. Thank you for your cooperation with 

the MIRC process. 

Sincerely, 

Linda 

~t;~~ 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. S lIile 110 1 • Baltimore, Maryland 21201-2)0) 

Telephone: 410.767.4500. Fax: 410.767.4480. Toll Free: 1.877.767.6272 • TrY User'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 of the 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 Nonattainment Area. 

A Copy of the newspaper notice is attached for your 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:1 Ie: \Documents and Settings\rcarro ll\Local Settings \ T emp\gwa60. tmp.html 

Page 1 of 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 :6allimQJeC ityEnVi[Onmental tteallhPirector 

To: 13aHimoreCOYl1tyEnyirOnmenlaJHealJbPirector 

To :6altimO[e ... CounlyEl1yirO nmenlalHealtb.DjreclQJ2 

To: Calvert County Ellviron menta I 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 CQuotyEnVi roome nta I HeaJthOirecl0 r 

To : HowargCouotyEnvi[onmentCiIHealth .. PJrector 

To: Kent County EnvironmentaJHealthPirectQr 

T 0: 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: Talgot CQunJyJ;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 

12/27/20079:50:17 AM 

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 of the 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 of the 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 of Maryland Public Hearing 

MARYLAND 

PM2.5 SIP Public Notice and Release for Comment 

This is to notify you that the state of Maryland - Maryland Department of the 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 of the 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 of the 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 of the newspaper notice is attached for your review. 
--. MARYLAND DEPARTMENT OF THE 4 __ ENVIRONMENT 

MD E 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 at the Maryland National Capitol Park & Planning Commission, 8787 

Georgia Avenue, 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 

concern with the" Fine Particle PM2.5 State Implementation Plan and 2002 Base Year 

Inventory" for the Washington DC-MD-V A Nonattainment area. This SIP was released 

for public comment and review on December 27,2007. 

Prior to this hearing the public was urged to express their concerns via the standard US 

Postal Service mail or by email submission. Every written mail response or email 

comment received in Maryland on behalf of the 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 of Maryland, Virginia and the District 

of Columbia. 

Maryland received comments by mail or by email prior to the scheduled public hearing. 

All comments received at the public hearing and prior have been responded to and appear 

in the composite "Response to Comments" section found in Appendix _K __ of the 

Appendix to the State Implementation Plan (SIP) for Fine Particle (PM2.s) Standard and 

2002 Base Year Inventory for the Washington DC-MD-VA Nonattainment Area. 
MWAQC PM2 .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 

1 William Skrabak, on behalf of the City of Alexandria 1/30/08 VOEQ 

2 Jeffrey Holmstead, Bracewell and Giuliani, on behalf 1/30108 VOEQ 

of Miran! Potomac River LLC 

3 Jeffrey Holmstead, Bracewell and Giuliani, on behalf 1/30/08 MOE 

of Mirant Potomac River LLC 

4Ana Prados and Mike Town 1/29108 VOEQ 

Sierra Club, Virginia Chapter 

5 Flint Webb, Fairfax Federation of Citizens 1/30/08 VOEQ 

Associations 

6Julie Crenshaw Van Fleet 1130108 VOEQ 

7 Air Quality Public Advisory Committee 216/08 MWAQC 

8RogerWaud 217/08 OCOOE 

gTom Ballou, on behalf of Virginia 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 

12 William Skrabak, on behalf of the City of Alexandria 2/11/08 OCOOE 

13 Jeffrey Holmstead, Bracewell and Giuliani, on behalf 2/11108 OCOOE 

of Miranl Potomac River LLC 

14 Elizabeth Chimento 2/11108 OCOOE 

Appendix K Attachment 1 - Page Number: 1 March 7. 2008 
Comment 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 C himenlo 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 lhal the 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 of the PM,. NMOS. as weR as further 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 of the cilizens of Ihe region. 

health impacts around the PRGS. 

The altainment plan requires thai PR GS perform an ambienl air qua"ty analysis when the methodology for such an 

analysis is finalized. The results of this sludy may show Ihat addilional controls on PRGS are needed 10 ensure the PM,. 

NMOS is mel. 

3 ATSDR Health Consultations for River Terrace in the District and the Jutie Crenshaw VDEO MWAQC and the stales win review and consider the identified health consultation sludies. 

Potomac River Generaling Station in Alexandria should be reviewed. Van Fleet 

4 The SIP should address the potenlial impact of the 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 of the 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 calegories for 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 of various 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 greater concern if considered cumulatively. Yel Ihere is no current plan shows how we 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 of the 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 how the 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 and justify its adequacy as a margin, those modeling analyses that 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' 

MW AQC 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 of evidence 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 of Governments 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 below the 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 of Alexandria, 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 

How wilt 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 

attributed to 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 of the drafl attainment plan discusses the changes made to the major stationary 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 that there 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 or modified 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 of Alexandria 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..:_ 

MW AQC PM2 5 SIP Appendix K Attachment I - Page Number: 3 March 7. 2008 
i; 

E.c Comment Commenter Recipient Response EE 

oz " ::J 

The proposed PRGS permit reduces emissions from the baseline year for this facilty. MWAOC and the states believe 

that the proposed permit 1MB improve air qualty and is not contrary to the goals of the 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 of this study may show that additional controls on PRGS are needed to ensure 

the PM25 NAAOS is met. 

MWAOC and the states do not support the approach of setting 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 of a facility. MWAOC and the states believe that the 2009 projection year 

inventory is quite conservative, 

12 The attainment plan does nol discuss additional RACT IRACM in City of Alexandria 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 of a suite of measures on whethenhose measures 

can collectively advance the attainment dale of a 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 of the draft attainment plan _ 

13 U.S. EPA's Clean Aif Fine PaJticulate Implementation Rule suggests City of Alexandria VDEQ, MWAQC and the slates disagree with the comment. The justification for examining monitoring and opacity standards is 

the use of more 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 basis for 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_r daily 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 of the reduction of the daity standard to 

35uwm', 

15 Education of the public on the heaHh related issues of fine 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 air quality. 

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 of Alexandria 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.input from several Il!jjional planning group~uchas th"Mkl-AtlanticlNortheast Visibility Union (MANE-V\)}, 

MWAQC PMV SIP Appendix K Attachment I - Page Number: 4 March 7. 2008 
c ~ 

~1l Comment Commenter Recipient Response I 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 or an 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 of 2010. 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 lor inclusion 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 of Alexandria 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 of Alexandria 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 of Alexandria VOEO, The goal of the 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 of highly conseMltive micro-scale modeUng thaI indicates the pOssibility of a 

"hotspot" in the City of Alexandria 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 PM25 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 Analysis for 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 of the NAAOS in the City of 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 of the 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 spalial field feature necessslY to complete the UAA. EPA expects that this component wiM be added in the next 

version of MATS and VDEQ wiD complete the analysis upon release of the 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 has the authority to 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 of lhe NAAOS in the City 01 

OCOOE Alexandria or elsewhere within the nonattainment area. 

The PM SIP is a regional document to address the regional PM health concerns within an EPA deSignated 

nonattainment area. The SIP therefore provides a nonatlainment control approach to health concerns that are jOintly 

shared by al jurisdictions in the designated metropolitan Washington area. 

23 An FRM monitor should be sited in the City of Alexandria and at other Julie Crenshaw VDEQ, For a number of reasons, il is impractical to locate PM"" FRMs near ovelY 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 of Virginia is considering siting a 

Rogerwaud MWAQC new FRM monilor in the City of Alexandria. Two special purpose monitors located near the PRGS are providing data on 

the impacts of the lacility on 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 of Alexandlia 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 air quality analyses. EPA has not yet published 

done in a timely manner. It also suggests that methodology to modeling guidance for PM,. pollution. Use of published 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,s chemistlY 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 by VDEQ 

lor sta&onary soun:es. which has been approved by USEPA to management. This language was included to account for the lact thai the requirements of the ambienl air quakly 

model primary PM" impacts. VOEQ shaH conduct an ambient air methodology are not known so thai a reasonable timeframe cannot currenlly be fixed. HOlMlver. VOEQ can require that 

quality analysis of the emissions of PM, sfrom the Mirant Potomac PRGS subm~ a prolocol once the final methodologies are approved by the SAPCS within a ceriain lime frame. for 

River Power Generating facility VDEQ shall complete this analysis instance 60 days. Section 9.4.3 has been updated to rellect this change and now reads: 

WIthin 120 days of adoption of the SIP by MWAQC. 

Based on a Schedule and protocol to be established by VDEQ aller US EPA promulgates fmal rules for PM" analySiS. 

or US EPA promulgates revised implementation guidance or policy for PM2.5 analYSIS. or VDEQ establishes a more 

appropriate implementation methodology for PM, s . Mirant Potomac River Power Station shall conduct an ambient air 

quality analysis for the emissions of PM15 from the facility. No later than 60 days aller approval of the Implementation 

method%iiy by the Virginia State Air Pollution Control Board. Mirant Potomac River Power StatIOn shaH proVide to 

MWAQC Plvh5 SIP Appendix K Attachment I - Page Number: 6 March 7, 2008 
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VDEQ a detailed protocol OUUining 0011\1 the facility will implement the approved methodologies VDEQ Will make thIS 

document available to the public by publishing this protocol on 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 emissions from 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 document for the nine jurisdictions in Northem Virginia VOEQ 

that are II part of the Washington, DC-MD-VA PM2.5 nonattainment 

area: 

1. For the 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 

emissions for the 9 Northem Virginia jurisdictions 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 ot the 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 

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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 how airport construction emissions are Metropolitan development of specific airport emission inventory fine 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 attributable to airport construction in the StP can be determined at the time the 

information is needed. 

29 The commenter provided a list of voluntary local air quafity City of Alexandria 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 graph through 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 appear to 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 of ammonium sulfates and one for 

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 of the 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"'rs which are stationary when operated but could 

operated anywhere in the region. 

34 Section 3.2.2 - "or county-equivalent" should probably be defined Flint Webb VDEQ Since MWAQC area inventory is calculated at county level, the term 'county-equivalent" is not relevant in the discussion 

earlier on in the 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 of the Section 3.2.3 (Onroad mobile sources) to der_ what COf'Istitute /llObile 

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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 whV ammonia 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 a jog indicating that the x-axis is not FtiotWebb VDEQ The range of !he V axis 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 14.0 YAU 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 slaff and 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 of growth 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 of the 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 if they 

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 il associated 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