GOVERNMENT DCo OF THE DISTRICT OF COLUMBIA

District Department of the Environment F r * * * i. v .

Office of the Director

APR 4 2OC

Al a& (t21)

APR -. 2 2008 RECEIVED Mr. Donald S. Welsh

Regional Administrator, EPA Region 3

Mail Code 3RAOO b 4 08

1650 Arch Street

Philadelphia, PA 19103-2029 OFF1CEOFREG1ONALADMI°’

Dear Mr. Welsh,

Pursuant to the authority set forth in the District of Columbia Air Pollution Control Act of 1984 (“the

Act”), Mayor’s Order 98-44, effective April 10, 1998, and Mayor’s Order 2006-61, effective June 14,

2006, the District of Columbia is hereby requesting approval ofthe attached State Implementation Plans

(SIPs) pertaining to attainment of the Fine Particle (PM 2.5) National Ambient Air Quality Standards(NAAQS).

Please find attached:

Three (3) copies ofthe SIPs with appendices that include:

- The 2002 Base-Year Emissions Inventory;

- The Attainment Demonstration for 2010;

- An analysis ofreasonably available control measures;- The Contingency Plan;

• The public hearing notice and affidavit of publication; and• The hearing officer’s certification.

• A CD containing an electronic version ofthe SIPs plus the emissions inventory in NW format

Your expeditious review and approval ofthe attached documents is requested. Should you have anyquestions or require additional information, please contact me on (202) 535-2615 or Ms. Cecily Beall,

Associate Director for the Air Quality Division, on (202) 535-2626.

Since el

George S. Hawkins

Director
GOVERNMENT OF THE DISTRICT OF COLUMBIA

Department of the Environment

***

Air Quality Division

MEMORANDUM

TO: George Hawkins

Director, Department ofthe Environment

FROM: Cecily Beau

Hearing Officer

DATE: February 12,2008SUBJECT: Hearing Officer’s Certification for the Public Hearing on Air Quality

Control Measures

This is to certify that, pursuant to the enclosed Notice of Public Hearing published in the

Washington Times, a hearing was held at approximately 6:00 p.m. on February 11, 2008 to give the public the opportunity to comment on the draft State Implementation Plan (SIP) for Fine

Particle (PM2.5) Standard and 2002 Base Year Inventory.

Cecily Beau ofthe Department ofthe Environment, Air Quality Division, represented the District. There were eight attendees who signed the attached attendance sheet.

Testimony was presented by:

1. Jessica Daniels

Buchanan Street, NW

Washington, D.C.

2. Jeff Holmstead

V

Bracewell & Giuliani
Appendix K

Public Hearing Notices

Public COmment Summary and Response
LEGALS j LUIALS 1 j LEIIAI.S LESALS LEGALS

MD E

Maryland Department of the Environmen

Notice of Public Hearingon Air Quality Plan

beMaryland Department of the Env tnuml (MUll) will hold a Public Hearing on a State Iniplemepiation

Plan (SIP) addressing theAnnual Pine Particle (PM 25) Standard for the WaslungconDC-MD-VA Nonattain

snent Area. The Mishlngiun DC-MD-VA Nonartainrneni Areaincludes he following Maryland counties;Charles, Frederick. Montgomery end Prince Georgc. The Hearing will be held on:

lanuary3fl,2008 at fii00 PM at the Maryland Nadonal Capitol Parkandt’IaimirtgCosiimlssion, First Flour

Auditorium, 8787 Georgia Avenue Silver Spring, Maryland.

The Public Hearitiwill be held as required by federal law (cicanAirActat 32 u.S.C. 7410 (a) dod 40 CFR 51.102).The proposed plan is rirlgd the Stare ImpleinentaUorz Plait (SIP?fr#Annuai This Particle (PM Z.5)SWn4ard and 2002 Base iisarIrweitioiyfor the Waskiizgfarz1)C-MD-VA No,laUain,nentArea. the plan contains emission in

aentorles. control me isures an ati’unme-st derrLonstratlms and moLrichicle emission budcts this plan con

tabs the b iso year 2002 air pollutint emtsslnns inventory and 2009 proleeted mseniory which sen ea ax the basis for all planningactivlties related to theAnnusl PineParticle Sianthird for the Washington DC-MD-VA Nortattainment Area.On December 12,2007. the Metropolitan WsshingtonAir QualbyCommittee (MWAQC) approved the proposedplan for release fr public review and comment. After consideration of commeBta received, theplan will be fi nalized and submitted to the United Slate linvlronnsental Protection Agency.

The SIP documenthas been made avaiIabl on the Maryland Department Of Lbs Euvironments.Wehsite at

1lnrLto,mde,aiate,uicLcriui2rnramsIAirProgrsmsIiir plsnninglindex.asp titled the ‘S’lan to ImproveAtr Quality in thetMishinguin DC-MD-VA Region” Noic; thepubliclibrarysyslemsinlhe regloncanbe usedfnr In

temet access to view the document.

Copits of the document can he viewed at the followi.ngiocatlons:

1. Maryland Department of thelinvironment Office, AirandRadiatlon Management

Admmtstrttion J800’.’ iahinlllonBoulevard SUIIC73O Ealijanore Maryland Contact Ra,ulall Carroll or Brian Hug.

2, MelropalitariWashinglon Cornell of’Governtnents, Suite 300,777 North Capitol Street, NE, Washington, DC20002 -Contact; Jeffrey King

Comments may be presented at the hearing, mailed, emailed, or faxed to Brian 1, Hug, Maryland Department of the Envimnment,Arrand Radiation Management Admlrilstratldn. 1800 WashIngton Boulevard, Baltimore, MD,21230, PasS 410..537-4223 bhug@mde.state.md.us to be received before close of business January 30,2008.

hearing impaired person may request that an interpreter be present at the hearing by notifying MUll flv (5) busineasdays beforethe hearing. flY via Maryland RClay for the hearing impaired is (410) 537-4396.

For more informatloncontact Randall CarrOll, Air Qoslily Planner at (4101 537-3232 (Toll (neC In Maryland call

(800) 633-6101 ext. 32521 or RCarro1l@mde.slstemd.us.

December 27,2007 62413S

MWAQC PM25 SIP Appendix K Public Hearing Notices -Page: 1 March 7, 2008
UDAJ

GOVERNMENT OFTHE DISTRICT COLUMBIA

DEPARTMENT OF ThE ENVIRONMENT

NOTICE OF PUBUC HEARING

ON AIR QUALITY ISSUES

Netico is hereby glean that a public hearln will be held no

Moudairs February Ii 2000 at 600 p.m. hr the Sib Floor confer

ence room at 51 N treet. NE, Wusttlngtnn, D.C. Tills hearlagprovides Ininrested parties op opportunity to cunairoot ott the

DiStrict’s State ImplementatIon Plan (5199 fur the WashingtonDC-MD00A Otto particle (P012.5) norraltalnment area.

The propusird ‘Stain ImpItmeitIStIDs Plan (SIP) i or Annual Floe t’attlcle dPM2.00 Standard arid 2002 Base seer riuentortr tar the

Waslilitgtsn DC-MbVA Nonatlalgnient Area”, consists of (I) a descrlppnn.dfebrst)ttg control measures 1(Ill an analysis of rita’sotlably avallabje cltettol measures. (((if molar oclilcie ends sloe budgets. 1(0)00 ettainmptthdemnosfratinn, nod (0) entitle.

gencp plugs ibr:falpre to attain lire air quality standard: The plan hIss Sotsialon me base year 3002 air pollutant emissiOns lonentety end 02009 prr,jeclrvd ineenlniry. shieS serves as the basio.For alliplhotilug schylticn related to toe standard.The Prepeirod SIP ears prepared by lire District nod the Mel pelltan Waahlnglorr Air Qualify Cnmrnilee (MWAQC) 1which cutotlsis nt elected nIrcnls 1mm the aliectril localities and

-represaniatjvet of If re stolen arid SC trartnpyrtaliOn aod air quality ilattnIng agencies. Tile ylznr is iritivaded In show tlte paogcesub&ng made to Impecac arr quality n the Washleetun -noflatlaittifletlt anna and tire effOrts underway In assure that all

steps are taben 10 reach lire iedernl health slaedead

for PM2. by 2000. F.IWAQC preparon fire plan to comply wilts the Clean Arr AC Arrrerrlments ot 1990. 1 Ire tederal Clean Air

Floe Particle fmplenientatisn talc, and galatance for implementatIOn of tire 5997 PMZ.S Standards. On December 12. 2007.

MWA 9Capproved the proponed plan, and DC and the states

are mousing ii br public reniew and cumcsenr.Tlrc prsposed SIP revisions are available tam public review San

to0 normal buynrss Snort at the of Pens of lire Dlntrkt Depart.marts vi tire Enairnrrnveof 102(001. 51 ft 50-net. NC. 110dm 6051, Washingino, D.C. 20057; lit Metropolitan Wahinotoo Council of Goqernbveills, SuIte 300, p71 Nnrlti Capitol Streel. 96, Wash. iriglen, oc 20002. cfrn0-cI left Cf rip; and oil-line at httn:?Ahlr - ,‘nwcon.irt/uir-qoalilyiSlrnred%2nllectenepis/vrmSfAl

rm6.asgv hair: the puslic library system in 11w District can bu used I or Inlaniet OCCOSS to ulew lire dncunrerrL

inlefeatati p-irlhin Wlnlvnrj Ia tqstlfy r)rhls hooting must Sub mit in wrlllirg fOrte homes. adriresnes, wieplrnoe rrumlteru and siirlialiiin, if any. Itt Ms. Crystal Prndlur at til)Oli 1202-535-22571

ho 4:00 p.m., February 15, 2000. fin written comnlarrts Will be a000pteil alter Felrrrrvry 11, 2000. rot nrow irlinrmatlon, cailMo Cerily Snail an 202-535-2020 or email her at Ce clly,be all tybc.gov

MWAQC PM25 SIP Appendix

K Public Hearing Notices - Page: 2 March 7, 2008
SiP is the pine developed by the Cootmpnweatth in srd’rr to foley 55 respon$ibiliIis under the federal Clean Mr Act to attain and main tain the arttbicnt air quality standards promulgated tty tile (1.5, En-al ra,imentui Protection agency (EPA) under tile Act.

Purpose of notice’ DEQ is seekin 0cOmments on the uvurali plan, In. cluding Ii) the atralemont plan, Is) the analysis of reasonably avail able control ninasures, (iii) the attainment demonstration (in) the contrngcncy plans fpr failure to attain the sir qaaiity standard, (a) mobile source budgets, and lvi) the base year 2082 aIr pollutant emissions iotentnry. The base year 2002 air poi)utint emIssions in ventory hon beea prepared in response to Ilte emission Inventory re quirements nnifr §172lc) of the tederal Ctean Air Act nt accordance with 40 CUR 51,010,

PublIc comment period: December 28, 2007, to January 30. 2008

PublIc heoring- George MasOn High School, 7t)-f Lhi’sbarq PIke, tells Church. Viroinla (willeo ,viilhin 3distance of the W”,f C,- 1i5 Church Metro Station) at 7:00 pjs un Jane-ary 29, 2000.

Description of proposal: The yr000sod rcvivinn, State impli’mooi Son Plan (SiP) fur file Annual line P-irllr,ulata l°M2.5) Standard and tIre 2q02 Base Year inventory tirr the Wushnrptsn. DC MD-VA boost thininr’nl Ares,” was prepared by the Metropolitan W,nnhsioptnn Air Quality Committee (IiIWAQCI, .nthitli consists of Clotted ofbciols truer lbs attested is-ahilies ,iird repreonotalives of otats trantporlu iron red air quality etaenin agencies. The plan is intondeij to show the nromrss heoig waste in improve air quality in the Wasltinsjtou riooatturnmeel iirCil Son lire efforts underway to assure that iii ncr. rsceiy slops are lkei, to reach the federal hr’olili st,sridrd for ‘122.0 by 7S09 Mi’MQC prepared the plait to comply with the Clean Art Act Arnpnrtmtnts of 1990 and with federal impiementotun geld soce

Fedurol Infrinnetion- This notice in being given te ‘ify thy ysirinc particIpatIon )t-ijeirerfltflls of fl-dmal rcqiiii’lronr, (lb OCR St 0?i The prOposal will he submitted ass re-soon t th COnv,r’unaeith of V,g ‘ret Oil’ unrter tt8(al rh the ledgrsti Clean Air An acnirr daocc will, tO COO 51.104. uI prw,ssns of lh proprreai arc’ ylerined to ha Suhlm,ttnrl as a revision lv lily Ci noons- nullS ri Virgiula sip

Hwwto 000iinentr DLQ ar.rrpl’ wrnlti’n r ornoento by n n-wi, 15 ‘sire lie rmvnsmssiso. and ousfol mail, is onoop ro cs 005ylototi), WRi’Tt’4 COMMENTS YOSt i’.CSUD( 1118 FULL NAME ACIJOESS. AND ttl(p[fOgE ir’tJMRtnt 0r pq3Q COMMFST1bC AND op RECEiVED BY 0(0 iT 5-00 r Y 09 THE LAST DAY OF tHE CO9MCNT PERti3D (JANUARy 30, 2000). Duo to problcms win’ the noality at facsimile transmissions, cumn’colnlyure uncunrugn,j w pros ie the signed cirniinal by postal mail within one ss-eek, exit Trsl and writ

lvii cnmment are accepted at tfte public hewing SEQ ‘rOtOrs that COmm,’nts Ire pros clad in writing, alonq with any Ouops-’rng docu ments or evhihifs. All lestirenrny, ‘ohibita and decnrueinhs rcrieed

arc ps’S of the puhic record Please note this prnpo plan is be ins cn’rrnrreotly reviewed by the u.S. EPA.

To review proposal: The Proposal and any stippnrtr’iq dn:jrr’rtu ar’ unalstble no tins DEQ AIr Public Notices fur Olu snob silt http:/Jwww deq ergrnia.ovJhircfmlrtieg/pianotosh 1riThe ilac umoets may also be abtained by contacting the SEQ rcprecenlacs-o nomad below The public may reeiew the documents between 8 30

n.m. and 4.30 P iii. SI each business day until the close of tl nyse-c cuenuTnery period at the Following locatinq; 11 OEQ Mon She’) 01 (ice. 8th Floor, 629 [. Main Street, Richmond, Virginia. sc-i coy aog awl 2) SEQ Northern Vrirria Regional Dffic. 13801 Coon Cnorl, Weixibridge, Virginia. 703-583-3850,

Contactfor publtc comments, document requests end additional In formution. Dmis Mct,eoct, Air Quality Planner, DPparL’ennt of Air Data AnalysIs and Planning, Department of Envlronmo5ai Quality, P.O. Bonn 1105. Richmond, VA 232tn (phone 804408-41°7. fan 0)34- 608-4515, email damcleodcleq,vninia gout

1105 OslO: Llscember 78th, 2007

MWAQC PM25 SIP Appendix K Public Hearing Notices - Page: 3 March 7, 2008
List of Comments Received on the Draft PM2.5State Implementation Plan for the Washington, DC-MD-V

Nonattainment Area

Comment Date

Number Commenter(s) Received Recipient

1 William Skrabak, on behalf ofthe City of Alexandria 1/30/08 VDEQ

2 Jeffrey Holmstead, Bracewell and Giuliani, on behalf 1/30/08 VDEQ

of Mirant Potomac River LLC

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

of Mirant Potomac River LLC

4Ana Prados and Mike Town 1/29/08 VDEQ

Sierra Club, Virginia Chapter

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

Associations

6 Julie Crenshaw Van Fleet 1/30/08 VDEQ

7Air Quality Public Advisory Committee 2/6/08 MWAQC

8 Roger Waud 2/7/08 DC DOE

9Tom Ballou, on behalf of Virginia DEQ 1/29/08 MWAQC

10 Marilyn Powers, U.S. EPA, Region III 1/30/08 VDEQ

11 Charley Baummer, on behalf of Metropolitan 1/30/08 VDEQ

Washington Airports Authority

l2William Skrabak, on behalf of the City of Alexandna 2/11/08 DCDOE

l3Jeffrey Holmstead, Bracewell and Giuliani, on behalf 2/11/08 DCDOE

of Mirant Potomac River LLC

14 Elizabeth Chimento 2/11/08 DCDOE

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

Nonattainment Areaa

C

al

Comment Commenter Recipient Response

General Comments on SIP

I The SIP include reference to the scientific community’s insistence Elizabeth Chimento DCDOE The main purpose of this attainment plan Continues to be demonstrating compli

that the annual 15 ug/m 3NAAQS is too high andshould be reduced ug/m’ annually and 65 ug/m’ daily. FRM data show that the region has already 

to 13-14 ug/m’ to be protective of human health. ug/m’ on an annual average and 65 ug/m’ on a daily average. While lower leve

. and the states do not agree that it is appropriate to comment on whether the NM

human health protection in the attainment SIP.

2 The SIP should include additional information on the health benefits Julie Crenshaw VDEQ, Language has been added to the attainment plan to indicate that attainment of t

• expected to accwe from implementation of the plan, including the Van Fleet, AOPAC MWAQC quality improvements, will have a positive influence on the health and well-being 

health impacts around the PRGS.

. The attainment plan requires that PRGS perform an ambient air quality analysis 

analysis is finalized. The results of this study may show that additional controls 

. NMQS is met,

3 ATSDR Health Consultations for River Terrace in the District and the Julie Crenshaw VDEQ MWAQC and the states will review and consider the identified health consultatio

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

4 The SIP should address the potential impact of the use of pollution Julie Crenshaw VDEQ, MWAQC and the states do not believe that the attainment plan is an appropriate 

control additives such as TRONA. Van Fteet, AQPAC MWAQC specific facility’s Operational considerations. Such details are routinely examine

the normal permitting process.

5 Direct primary PM,. 5emissions, while not a large part of the inventory, AQPAC MWAQC MWAQC and the states agree that in the future more attention needs to be paid 

are increasing and may need to be addressed in the future, emissions inventories, Much more federal guidance, including a more robust te

emission factors that may be developed for various source categories for that d

and local agencies. This information needs to contain information on both filter

An area needing work is the area source emissions inventory. The chemistry of 

scientists, and until more information is known about PM, 5formation, the relativ

categories, and the need for area source controls, cannot be adequately evalua

6 In Section 2.6, the OCMs and the sulfates as mentioned and depicted AQPAC MWAQC MWAQC and the states agree that the science related to OCM/aerosots and VO

are of greater concern if considered cumulatively. Yet there is no current plan shows how we will attain the annual PM2.5standard changes in the 

dialogue regarding them, and in this same Section the primary be a need to further develop our understanding of the complex Science of PM2.5 

aerosols, given the capacity to create new PM, should be dearly region has completed a plan that shows how the region will meet the current an

explained. The term 0CM should be included in the glossary.

7 Section 9.4.5 dubs .5 percent a “margin of safety.” The SIP should AQPAC MWAQC The commenter appears to be referring to the statement in Section 9.4.5 that no

clearly explain this percentage and justify its adequacy as a margin, those modeling analyses that show that attainment with the NASQS will be reac

since it may not be adequate. - safety (i.e., estimated concentration below 14.5 ug/m 3for annual PM15 and 62 u

supporting material.’

The weight of evidence range, as suggested by EPA guidance for the annual P5

MWAQC PM2.5 SIP Appendix K Attachment 1 - Page Number: 2 March ,2008
C

Comment Commenter Recipient Response

to 15.5 ug!m. Should the design values predicted by the regional modeng fall 

guidance on what must be included in a weight of evidence showing to demonst

be achieved in 2009.

Modeling results that fall beneath 14.5 ugfm 3,such as those for metropolitan Wa

weight of evidence demonstration. Modeling, which includes the additional suite 

hour ozone attainment plan, projects the area’s 2009 design value to be 13.9 ug

3.

attainment demonstration.

Control StrategylMeasures

8 The states and the Metropolitan Washington Council of Governments AQPAC MWAQC MWAQC and the states agree and appreciate the recognition for the considera

for their considerable efforts to reduce particle pollution below the quality in the region, induding adoption of local innovative programs.

annual standard.

The commenter urges that alternative and non-air-polluting energy

sources be promoted by measures like Green Buildings and LED

lighting.

9 The draft SIP does not adequately outline a process that will assure City of Alexandria, VDEQ, MWAQC and the states disagree; they believe that the programs outlined in the 

that the DC-MD-VA Region meets the NAQS standard for PM2.5. Roger Waud DCDOE accomplish the SIP goal. The main purpose of this attainment plan continues t

How will existing permit programs be specifically implemented, or 1997 standards of 15.0 ug/m 3annually and 65 ug/m 3daily. FRM data show tha

enhanced, in regards to PM25. 1997 standards of 15.0 uglm 3on en annual average and 65 ug/m 3on a daily av

attributed to many of the control programs implemented in previous attainment 

and supplemental control programs, as outlined in the draft attainment plan, wil

emissions of PM25.

MWAQC and the states agree that it is important to be mindful of the 2006 PM 

Section 8.2 of the draft attainment plan discusses the changes made to the ma

in regards to PM5.

Section 8.4 notes the intention by the state agencies to adopt further PM25 non

including requirements for precursor emissions, controls, and offsets, when the

10 The attainment plan should contain.more rigorous monitoring, Alexandria, VDEQ, MWAQC and the states disagree with the comment that current permitting, enf

permitting, and enforcement programs. Rigorous monitoring Elizabeth Chimento DCDOE requirements are lax and that there is an absence of a compliance and enforce

programs and more severe limitations are necessary due to model major new source review permitting, either as new or modified sources, must in

uncertainty. Lax permitting, monitoring, and compliance programs achievable emission rates (LAER). Monitoring and enforcement programs in th

allow increases of emissions over this attainment plan’s emissions (NRO), VDEQ, MDE, and DCDOE are strong.

inventories and caps.

11 VDEQ’s proposed permit for PRGS is contradictory to SIP goals. City of Alexandria VDEQ, MWAQC and the states disagree. The main purpose of this attainment plan co

The inventory used in the attainment plan regional modeling exercise DCDOE with the 1997 standards of 15.0 ug/m 3annually and 65 ug/m 5daily. FRM data 

is less than proposed permit limits and therefore underestimates the 1997 standards of 15.0 uglm 3on an annual average and 65 ug/m 3on a dail

emissions.

MWAQC 25 SIP Appendix K Attachment I - Page Number; 3 March 7, 2008
C

e

Comment Commenter Recipient Response

The proposed PRGS permit reduces emissions from the baseline year for this f

that the proposed permit will improve air quatity and is not contrary to the goats 

In addition, the attainment plan requires that PROS perform an ambient air quali

. - such an anatysis is finalized. The results of this study may show that additional 

. the PM25 NPAQS is met.

MWAQC and the states do not support the approach of setting projection year e

limits or potential to emit. Regional modeling inventories are based on actual e

Projected emissions are rarely, if ever, as high as the potential to emit of a facili

extrapolated using a base year’s actual emissions inventory and applying a con

EPA. In some instances, projected emissions are adjusted based on control es

are almost never based on potential to emit of a facility. MWAQC and the state

inventory is quite conservative.

12 The attainment plan does not discuss additional RACT/RACM in City of Alexandria VDEQ, 40 CFR 51.1010, which delineates requirements for reasonably available contro

enough detail. DCDOE available control technology (RACT), predicates the implementation of a suite o

can collectively advance the attainment date of a nonattainment area by one ye

area is currently attaining the PM2.5NAAQS, based on FRM data for 2003-2005 

suite of measures to advance attainment. This explanation is provided in sectio

13 U.S. EPA’s Clean Air Fine Particulate Implementation Rule suggests City of Alexandria VDEQ, MWAQC and the states disagree with the comment. The justification for examin

the use of more stringent monitoring and opacity standards, DCDOE discussed in EPA’s Clean Air Fine Particulate Implementation Rule (72 FR 2058

Virginia’s current opacity standard of 20% allows PM emission requirements. RACT/RACM requirements are predicated on advancing the atta

increases without adequate review. Opacity limitations should be metropolitan Washington area. Unless a facility undergoes a major modification 

strengthened to no more than 10%, permitting process, in which case LAER must be applied, or undergoes a minor 

Available Control Technology (BACT) must be applied, there currently is no bas

standards applied to major stationary sources.

14 Both proactive and piescriptive measures to reduce fine particle AQPAC MWAQC MWAQC and the states agree that additional measures need to be implemented 

pollution are of significant interest to the public and we encourage region, especially considering the pending new lower daily PM25 standard, Stat

their development and implementation. Pushing forward on these identity and develop new policies and programs to reduce emissions in the regio

initiatives now, especially since some require medium- to long-term

planning, is essential in light of the reduction of the daily standard to

35 ug/m.

15 Education of the public on the health related issues of fine particles AQPAC MWAQC MWAQC and the states agree that public education programs are an important 

should also be intensified, since it will facilitate future voluntary or human heath and improve air quality.

regulatory reductions for both fine particles as well as expected

requirements to reduce other pollutants with similar sources, such as

greenhouse gases.

Attainment Modeling -

16 CMAQ generally over-predicts during winter months and under- City of Alexandria VDEQ. The Model Performance Evaluation (MPE) included in the metropolitan Washin

predicts during summer months, Statistical metrics such as fractional DCDOE based on input from several regional planning groups such as the Mid-Atlantic

MWAQC PM2.5SIP Appendix K AttaChment 1 - Page Number: 4 MarCh 7, 2008
C

Comment Commenter Recipient Response

error and bias do not provide assurance that the model predictions the Ozone Transport Commission (OTC) and the Association for Southeastern 

meet the modeling performance goats on either a 24-hour or an all elements of the modeling platform, including the emissions, meteorology, an

annual basis. There is no observed error in model performance on extensive evaluation,

the end model result in the target year of 2010, The design value

calculations should include columns of maximum predicted values The results of the MPE for the metropolitan Washington area for PM25and its i

that reflect the model’s worst-case performance for this modeling model performance for surface PM2.5is good, with acceptable bias and error. 

domain. The analysis relies too heavily on the trend in observed guidance and includes the proper statistical performance metrics.

PM25 levels.

MWAQC and the States believe the issues identified by the commenter are not 

appropriate for inclusion in the attainment demonstration since attainment tests 

response_factors.

17 The analysis relies too heavily on the trend in observed PM2.5levels. City of Alexandria VDEQ, MWAOC and the states recognize that model results and projections will conti

DCDOE attainment demonstration that EPA recommends recognizes this by including m

analyses such as air quality trends to determine whether all available evidence 

emission_reduction_plan_will_suffice_to_meet the_NAAQS.

18 VDEQ should not rely on PM, 0as a surrogate for PM25 in the City of Alexandria VDEQ, MWAQC and the States not believe that the PM25 attainment plan is an approp

permitting process for PRGS. DCDOE permitting guidance. Such permitting concerns are more appropriately address

participation_opportunities afforded_the_public_during_the_permitting_process.

19 The SIP does not address the reduced operational loads of PRGS City of Alexandria VDEQ, The goal of the attainment plan is to demonstrate compliance with the 1997 PM2.5

that were important events in relation to the downward 24-hour . DCDOE

design level trends between 2002-04 and 2003-05. Chapter 9 -MWAOC and the States do not agree that detailed discussions of every facility

should include a thorough discussion, along with a timeline that 2009 are necessary.

matches the implementation of the regional programs with the FRM

monitoring results and include the effects of various actions

concerning PRGS on the decline in regional values.

Local Hotspots

20 Local hotspots should be addressed in the SIP. City of Alexandria, VDEQ. EPA does not define a hotspot in the implementation rule. The current EPA gu

Julie Crenshaw DCDOE attainment plans notes that local area analyses are required for areas within a r

Van Fleet, AOPAC, MWAQC concentrations at monitors within the federal reference monitoring network whe

Roger Waud, reference monitors in the region. There is no identified gradient in PM concentr

Elizabeth Chimento metropolitan Washington region. Therefore, by EPA’s definition. there is no req

. analysis. MWAQC and the states are aware of highly conservative micro-scale 

“hotspot” in the City of Alexandria even though current data from the monitors l

concentrations are well beneath the NAAQS. Additionally, FRM monitoring da

. show compliance with the NAOS. Regardless, the SIP does include requirem

concerns regarding emissions from PRGS through additional analyses, when m

required by Section 9.4.3.

MWAQC PM25 SIP Appendix K Attachment 1 - Page Number: 5 March 7, 2008
C

s

. Comment Commenter Recipient Response

21 The SIP should include either an Unmonitored Area Analysis or a City of Alexandria, VDEQ, MWAQC and the states believe that the most appropriate means to address th

Local Area Analysis for the Potomac River Generating Station and Julie Crenshaw DCDOE. from PRGS on the surrounding community is through the Virginia permitting pr

other large point sources. The regional monitoring network is not Van Fleet, AQPAC, MWAQC requirement for Mirant to prepare and submit a modeling analysis once federal 

robust enough to detect exceedances of the NPAQS in the City of Roger Wauct,

Alexandria that are caused by the Mirant facility, modeling tools are Elizabeth VDEQ is currently in the process of conducting the Unmodeled Area Analysis (

available, and the SIP is the appropriate means to address the Chimento, Sierra area. VDEQ is also part of the test group for the recently released beta versio

situation. Club, Flint Webb Software (MATS) which is the tool required to conduct the UAA. Unfortunately

the spatial field feature necessary to complete the UA. EPA expects that this 

version of MATS and VDEQ will complete the analysis upon release of the upd

22 The requirement for a Local Area Analysis for the Potomac River Mirant Potomac VDEQ, MWAQC and the states disagree. The Commonwealth of Virginia has the auth

Generating Station should be removed from the SIP. River LLC MDE, from the PRGS to determine whether the facility causes or contributes to excee

DCDOE Alexandria or elsewhere within the nonattainment area.

. The PM SIP is a regional document to address the regional PM health concern

nonattainment area. The SIP therefore provides a nonattainment control appro

shared by all 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, it is impractical to locate PM2.5FRMs near every sour

locations that have large PM25 sources, Van Fleet, AQPAC, DCDOE. PM2.5emissions in the metropolitan Washington area. However. the Commonw

. Roger Waud MWAQC new FRM monitor in the City of Alexandria. Two special purpose monitors loca

the impacts of the facility on air quality in the City. These data will continue to 

24 The language in Section 9.4.3 that requires an ambient air quality City of Alexandria VDEQ. MWAQC and the states do not believe the language suggested by the comme

analysis is deficient since it fails to insure that the analysis will be DCDOE Gaussian dispersion modeling will be a requirement of PM2.5ambient air qualit

done in a timely manner, It also suggests that methodology to modeling guidance for PM2.5pollution. Use of published guidance for other po

conduct such an analysis is not available at the present time, which that the highly complex nature of PM2.5chemistry may not make the use of gui

is contrary to existing EPA guidance. The language should be Gaussian dispersion modeling is eventually required, no federal guidance curr

revised to read: . PM2.5of this technique, which is multi-faceted and highly complicated.

Using an available Gaussian dispersion model, such as AEROMOD, The language included in Section 9.4.3 states that the timeline for submitting t

for stationary sources, which has been approved by.USEPA to management. This language was included to account for the fact that the requ

model primary PM25impacts, VDEQ shall conduct an ambient air methodology are not known so that a reasonable timeframe cannot currently b

qualify analysis of the emissions of PM25 from the Mirant Potomac PRGS submit a protocol once the final methodologies are approved by the SA

River Power Generating facility. VDEQ shall complete this analysis instance 60 days. Section 9.4.3 has been updated to reflect this change and n

within 120 days Of adoption of the SIP by MWAQC.

Based on a schedule and protocol to be established by VDEQ after US EPA p

or US EPA promulgates revised implementation guidance or policy for PM2. 5 

appropriate implementation methodology forP14 25,Mirant Potomac River Pow

. quality analysis for the emissions of PM25 from the facility. No later than 60 da

methodology by the_Visqinib_State Air Pollution_Control Board,_Mirant Potomac 

MWAQC PM2.5 SIP Appendix K Attachment 1 - Page Number: 6 March 7, 2008
C

. Comment Commenter Recipient Response

VDEQ a detailed protocol outlining how the facility will implement the approve

document available to the public by publishing this protocol on the VDEQ web

Technical Corrections

25 The SIP should be revised to include reference to the 24-hour PM2.5 Marilyn Powers, VDEQ MWAQC and the states agree. The SIP was revised to incorporate the comme

standard. U.S. EPA Region III

26 The SIP should be revised to reflect the fact that Virginia’s rule Marilyn Powers, VDEQ MWAQC and the states agree. The SIP was revised to incorporate the comme

capping emissions from power plants in the region is a state-only U.S. EPA Region Ill

requirement and is not part of the CAIR rule. The commenter also

suggested a minor editorial change for Section 9.3.1.

27 The commenter requests that the following revisions bit incorporated Thomas Ballou, MWAQC MWAQC and the states agree. The SIP was revised to incorporate the comme

into the SIP document for the nine jurisdictions in Northern Virginia VDEQ

that are a 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) to reflect

the BY 2002 emission estimates for these categories: 1) The

emissions for the 9 Northern Virginia jurisdictions coded under SCC

2810015000 should be moved to SCC 2810014000; 2) The

emissions for the 9 Northern 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

were included in the SIP inventory were originally developed by the

EPA and added to the National Emission lnventoiy as part of EPA’s

augmentation process. Since the SIP inventory was compiled, we

have discovered that EPA has reviewed these emissions and for

jurisdictions that were greater than 80% urban, those emissions were

zeroed Out of the EPA 2002 National Emission Inventory. Therefore,

we are requesting that MWCOG remove those corresponding

emissions from the PM2.5 SIP.

2. Changes in the BY 2002 emission inventory made above will

change the future year inventories and associated analyses and

documentation. Therefore, also update future year emissions and

MWAQC SIP Appendix K Attachment 1 - Page Number: 7 March 7, 2008
C

o

Comment Commenter Recipient Response

associated analyses and documentation in the main SIP document

and related appendices.

The recommended changes do not change the overall SIP

conclusions.

28 The commenter requests additional detail on an appropriate method Charley Baummer, VDEQ Through the MWAQC process an airports subcommittee was formed and discu

to determine whether and how airport construction emissions are Metropolitan development of specific airport emission inventory line items for regional airport

reflected in the SIP. Washington Airports the metric to examine all the emissions related to airport operations (constructio

Authority Stakeholders declined the offer to pursue airport specific emission inventory lin

estimate the construction emissions attributable to airport construction in the SI

information is needed.

29 The commenter provided a list of voluntary local air quality City of Alexandria VDEQ MWAQC and the states support inclusion of local voluntary initiatives in the SIP

improvement initiatives and asked that they be included in the SIP, measures identified by the commenter.

for no emission reduction credit.

30 The Figure (Figure 2-5) does not include data for March through Sept Flint Webb VDEQ Included data in the graph through December 2005 as requested and also to b

05. 2.

31 The text (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 

figure. The figure is of ammonium ion concentrations but the text provide information on ammonium nitrate and ammonium sulfate as requested.

discusses ammonium nitrates and ammonium sulfates. Perhaps

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 title was updated to better explain the content and terms of the figu

“Passive”). What are the units - I presume it is % by mass but it is not

stated.

33 Section 3.2.2 - Need to clarify the difference between area “non- Flint Webb VDEQ The difference between area “non-stationary” sources and mobile sources was 

stationary” sources and mobile sources. Perhaps examples like

mobile generators 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-eq

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 

MWAQC PM2.5SIP Appendix K Attachment I - Page Number: 8 March 7, 2008
C

Comment Commenter Recipient Response

need to be clarified. sources. Axea source section (Section 3.22) provides details about area source

make distinctions between area and mobile sources very dear.

36 This figure (Figure 2-10) still either needs much more explanation or Flint Webb VDEO The reason wtry ammonia is not considered a significant precursor is explained 

the whole section should be deleted. The figure shows that induding chapter 2 (section 2.8) immediately after Figure 2-10.

ammoniated compounds account for 65% of the SAND1MCH material

and yet we are not considering ammonia emissions. The minor

modification to the text from the previous version is an improvement

but does not go far enough.

37 Figure 2-11 y-axis should show a jog indicating that the x-axis is not Flint Webb VDEQ The range of the y axis in Figure 2-11 was defined from 14.0 to 17.5 in order to 

at zero or the x-axis should go down to zero. The figure makes it trend line. Extending the y axis all the way to 0.0 instead of 14.0 wit make the tr

look like the annual concentration is almost 0. Alternatively there labeled for design values for different years and the annual PM2.5 standard line 

should be a zig-zag line indicating that the axis is not at zero, dear.

38 Section 3.2.4 - Non-road airport vehicles need to be mentioned in the Flint Webb VDEQ All nonroad vehicles are part of nonroad inventory and so must stay in nonroad 

Area source section (3.2.2). source section.

39 Section 4.1.1.2 - Since the Pica sources make up a large portion of Flint Webb VDEQ Growth surrogates for different area and nonroad source categories were decid

the inventory it is important that the growth factors are correct, It agency staff and the Emissions Inventory Sub-Committee. Though the surrogat

would be good to compare some of the factors with historical growth comment above may not completely provide tree picture of growth for those cat

factors. Specifically a comparison with historical growth for the . appropriate surrogate available to us.

following is requested:

•Residential Fuel Combustion - Has there been an increase in natural Also, the commenter now should not be concerned about 50% growth for “Open 

gas usage that may off-set the household increases? removed from Virginia inventory as part of the public comment made by VDEQ.

“Open Burning - Using population as a growth factor means that it

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 the 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 municipal landfill emissions may grow

faster than simply the rate of population growth.

•Fugitive Dust - Using VMT as the growth factor implies that all

fugitive dist emissions are associated with on-read vehicles. Isn’t

much of it associated with constwclion activity?

Notes:

For additional detailed response to comments, please see Appendix K Attachment 2.

MWAQC PM25 SIP Appendix K Attachment 1 - Page Number: 9 March 7, 2008
presentations, is located at the Office of Air Regulatory Development of the Department

of Environmental Quality. The department contact to access this information is the

Director, Office of Air Regulatory Development.

As required by Section 2.1(h) of Appendix V of 40 CFR Part 51, below is a summary of

the testimony received and responses thereto. Included is a brief statement of the

subject, the identification of the commenter, the summary of the comment and theresponse (analysis and action taken). Each issue is discussed in light of all of the

comments received that affect that issue. All comments have been reviewed and

responses developed based on an evaluation of the issues raised in consideration of

the overall goals and objectives of the air quality program and the intended purpose of

the document under review.

1. SUBJECT: The commenter objects to the inclusion of the requirement for Mirant

Potomac River Generating Station (PRGS) to submit an air quality analysis forPM25 emissions once methodologies for such an analysis are finalized. The

requirement is found in Section 9.4.3 of the draft PM2.5SIP.

• COMMENTER: Mr. Jeffrey Holmstead of Bracewell and Guiliani, on behalf of

Mirant Corporation.

TEXT: The full text of this submittal, dated January 30, 2008, is attached to this

document. The following is a summary of main points made in the document.

• No technical or legal basis exists for the inclusion of this requirement in the PM2.5

SIP.

• Actual monitoring data do not support the conclusion that such an analysis is

necessary.

• The air quality analysis required to be submitted by PRGS has no relationship to

the PM25 attainment SIP.

• PM25 emissions from PRGS are well-controlled.

RESPONSE: In regards to the statement that no technical or legal basis exists

for the inclusion of the PRGS PM2.5ambient air quality analysis requirement in

the PM2.5SIP, VDEQ believes that the requirement is supported by a variety of

documents. 9 VAC 5-20-180 I gives the State Air Pollution Control Board

(Board) authority to shutdown a facility to prevent violations of the NAAQS:

Appendix K, Attachment 2 -Page Number:
for which emission standards are given in 9 VAC 5 Chapter 40 (9 VAC 5-40-10 et

seq.), 9 VAC 5 Chapter 50 (9 VAC 5-50-10 et seq.), and 9 VAC 5 Chapter 60 (9

VAC 5-60-10 et seq.) shall, upon request of the board, register such source

operations with the board and update such registration information. The

information required for registration shall be determined by the board and shallbe provided in the manner specified by the board.” 9 VAC 5-40-50 H requires

facilities to provide various reports at the request of the Board: “Upon request ofthe board, the owner of an existing source subject to the provisions of this

chapter shall provide notifications and report, revise reports, maintain records or

report emission test or monitoring result in a manner and form and usingprocedures acceptable to the board...” The Clean Air Act Amendments of 1990

(CAAA) notes in §1 72(c)(1) Nonattainment Plan Provisions — In General that

plans shall “. . . provide for attainment of the national primary ambient air quality

standards.” §1 72(c)(1) Nonattainment Plan Provisions — Other Measures

requires that plans contain emission limitations and other such control measures,means, or techniques as may be necessary or appropriate to provide for

attainment.

VDEQ agrees that the actual monitoring data currently available may not

necessarily indicate the presence of a NAAQS violation for PM2.5attributable to

PRGS. However, to a certain extent, these data are inconclusive. Ambient air

quality violations of the NAAQS are dependent upon meteorology; facility stackconfiguration; local area topography such as the presence of hills, peaks, valleys

and nearby structures; emission rates from any facility; regional load being

transported into the area; and a number of other factors. Emission rates from

any facility can be dependent upon fuel type; demand; limitations placed on the

facility by a variety of permits; and other operational and economic factors.

VDEQ agrees that there are several uses of air quality data in evaluating the

impacts from a facility such as PRGS. One of the most important uses identifiedin the EPA’s Guideline on Air Quality Model is the use of air qualitymeasurements “in a complementary manner to dispersion models, with due

regard for the strengths and weaknesses of both analysis techniques.” While air

quality measurements are particularly useful in assessing the accuracy of modelestimates, such measurements do not necessarily eliminate the need to apply a

model to assess an individual facility’s impact. Although it is possible to use air

quality measurements alone to assess NAAQS compliance, this approach would

Appendix K, Attachment 2 - Page Number:

2
VDEQ disagrees that the PM2.5air quality analysis, required to be submitted by

PRGS, has no relationship to the PM25 attainment plan. The facility operates

within the boundaries of the nonattainment area and is considered to be upwind

of many other nonattainment areas such as Baltimore and Cecil County in

Maryland.

It should be noted that the federal reference monitoring program for PM2.5in the

metropolitan Washington area is one of the most robust monitoring networks in

the U.S. Based on the data from this federal reference monitoring program, the

nonattainment area has demonstrated compliance with the annual PM2.5

standard of 15.0 ug/m 3.However, attainment plans often focus on specific

facilities as well as the overall regional air quality. For instance, facility-specific

RACT requirements may be enumerated within attainment plans, and facilityspecific requirements may also be used for contingency measures in attainment

plans as well as maintenance plans. An important part of the attainment plan is

the assumptions made for growth in various emissions categories and how such

growth is incorporated into the attainment plan. To take into account growth inemissions, VDEQ must often examine specific facilities or types of facilities todetermine likely growth rates. Therefore, specifying requirements or specifying

facility data for a particular facility is not a deviation from past or current

attainment planning practices. Certainly VDEQ believes that ascertaining

whether or not a particular facility, the operation of which has engendered

enforcement actions and significant public comment in the last few years, causes

or contributes to a PM2.5ambient air quality violation in an area that currentlydoes not contain a federal reference monitor, via an approved analysis

methodology, may be an appropriate topic for the PM2.5attainment plan.

Whether or not the description of ‘well-controlled” should be applied to the

existing PM2.5control devices at PRGS (electrostatic precipitators or ESPs) is

unclear. A comparison of tested emission rates, as provided by the commenter

in his January 30, 2008, submittal, to those required by the existing sourceregulations in 9 VAC 5 Chapter 40 Existing Stationary Sources indicates thatPRGS appears to operate at well below 0.12 lbs PM/mmbtu. However, a

comparison of those same emission rates, and emission limitations in the draft

PRGS permit, to limitations placed on new coal-fired boilers through the Best

Available Control Technology (BACT) process show that the limitations on new

coal-fired boilers may be somewhat more stringent.

Appendix K, Attachment 2 -Page Number:

3
2. SUBJECT: The commenter is concerned about the PM2.5impacts from the

PRGS power plant.

COMM ENTER: Mr. William J. Skrabak, Chief, Division of Environmental Quality,

Department of Transportation and Environmental Services, City of Alexandria on

behalf of the City of Alexandria.

TEXT: The full text of this submittal, dated January 30, 2008, is attached to this

document. The submittal is lengthy and requests many changes to the draft

PM2.5attainment plan. The paragraphs below group the suggestions and

comments into various sub-categories. VDEQ has responded to each subcategory separately.

(a) Comment: The attainment plan does not contain a detailed description of

how existing permit programs will be specifically implemented, or

enhanced, in regards to PM2.5 The attainment plan should contain morerigorous monitoring, permitting, and enforcement programs.

Response: It is important to note that for regional air quality and the

purposes of determining attainment of a NAAQS by a regional area,

federal reference monitoring (FRM) data must be used to show

compliance or noncompliance with the standard. The existing FRM

network in the metropolitan Washington area consists of 14 PM2.5

monitors and is one of the most robust monitoring networks in the country.

For years 2003-2005 as well as for years 2004-2006, this monitoringnetwork has demonstrated compliance with the 1997 PM2.5standards of

15.0 ug/m 3on an annual basis and 65 ug/m 3on a 24-hour basis. FRM

data for the year 2007 are not currently available for Maryland and

Washington, D.C. However, VDEQ has completed quality assurance

reviews and has certified the Virginia 2007 PM2.5data. These data show

that the highest measurements in northern Virginia reflect PM2.5design

values of 14.1 ug/m 3on an annual basis and 34.0 ug/m 3on a 24-hour

• basis, well beneath both 1997 standards.

This draft attainment plan is designed to address the 1997 standards.

Certainly the new NAAQS standards, which were promulgated in 2006

Appendix K, Attachment 2 - Page Number:

4
Section 8.2 of the draft attainment plan discusses the changes made to

the major stationary source permitting program in regards to PM2,5.

Section 8.4 notes the intention by the state agencies to adopt further PM2,5nonattainment permitting requirements, including requirements forprecursor emissions, controls, and offsets, when these regulations are

finalized by EPA.

In the 2008-2010 Grant Work Plan, of which both EPA Region Ill and

VDEQ are parties, VDEQ has a grant commitment to submit a draft NSR

SIP for PM2.5nonattainment areas no later than 6 months after EPA

finalizes the PM2.5NSR implementation rule. This commitment is found

• under Objective 1.1-Healthier Outdoor Air, Sub Objective 1.1.1 — More

People Breathing Cleaner Air, Work Plan Component — NAAQS NSR.

It is clear from these various paragraphs that VDEQ intends to adopt the

• EPA’s finalized version of nonattainment permitting requirements when

they become available. However, to include in the draft attainment plan

an outline of these requirements prior to publication of a final version

would be premature since EPA has published little regarding these new

regulations and since changes are always likely between proposed and

final versions.Additionally, including in an attainment plan specific requirements of the

new source review permitting program would be duplicative. The new

source review permitting program is published under a separate chapter of

the Virginia State Air Pollution Control Board’s Regulations for the Control

and Abatement ofAir Pollution. Changes will undergo public scrutiny ifrequired by the Administrative Process Act. Modeling requirements thatmay be necessary for the program are generally guidelines published by

EPA and used by many states across the country. If such details were

included in the attainment plan, any changes made to modeling guidance

or the new source review program would also necessitate a revision of theattainment plan, which is a time consuming, resource intensive process.

Therefore, VDEQ does not deem it appropriate or necessary to include

additional detail about the permitting program within the attainment plan.

Appendix K Attachment 2 Page Number

5
p

Response: VDEQ disagrees that the programs outlined within the

attainment plan are insufficient to accomplish the SIP goal. FRM data

show that the region has already attained the 1997 standards of 15.0

ug/m 3on an annual average and 65 ug/m 3on a daily average. These

accomplishments may be attributed to many of the control programsimplemented in previous attainment plans for ozone. Additional federal,

state, and supplemental control programs, as Outlined in the draftattainment plan, will continue to reduce precursor and direct emissions of

PM25.This attainment plan should improve air quality.

VDEQ agrees that it is important to be mindful of the 2006 PM2.5NAAQS

standard on a regional basis. For years 2004-2006, only one regional

FRM located in Washington, D.C. showed a 24-hour design value above

35 ug/m 3.The data for all states have not yet been certified for years2005-2007. However, VDEQ’s data have been certified for these years,

and these data show all monitors in northern Virginia have 24-hour

averages of no more than 34.0 ug/m 3.On a regional basis, these data

show that air quality is improving and appears to be attaining or nearly

attaining the 2006 standard.

Modeling uncertainty does exist and is documented as part of themodeling evaluation report. However, EPA has recognized the fact that

PM2.5models have intrinsic uncertainties due to many factors, includingbut not limited to the complex nature of PM2.5formation and the current

state of the science of PM2.5modeling. To address these uncertainties,

EPA requires the use of the modeling results in a relative sense rather

than an absolute sense. VDEQ must make comparisons between

modeling outputs for 2002 and 2009 then use these ratios with actual

FRM data to predict future design values. Direct model output results for

2009 may not be used to show future attainment status. The use of the

modeling outputs in a relative sense, coupled with the current improved air

quality in the metropolitan Washington D.C. area, does not support the

development of more stringent permitting requirements than those that will

be published for implementation of the PM2.5nonattainment permitting

program.

Appendix K, Attachment 2 -Page Number:

6
y

y

facility’s potential to emit or permitted levels to ensure that all levels of

operation by the new facility will not impact the NAAQS.

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 conservative growth factor, as required by EPA. In some instances,

‘projected emissions are adjusted based on control estimates. However,

projected emissions are almost never based on potential to emit of a

facility. Using such a methodology, region-wide would drastically over

inflate the point-source emissions inventory of an area. Drastic over

inflation of the projected emissions inventory would have the effect of

requiring costly and likely unnecessary regional control measureimplementation to meet the air quality standards and protect public health.

Such mitigation efforts cannot be supported if there is every reasonable

expectation that PM2,5air quality is good and getting better, as indicated

by the FRM data. Therefore, VDEQ does not support the approach ofsetting projection year emission inventories equal to permitted limits orpotential to emit.

VDEQ disagrees with the comment that current permitting, enforcement,

and monitoring program requirements are lax. Facilities that trigger major

new source review permitting in the northern Virginia PM2.5nonattainment

area, either as new or modified sources, must install technology deemed

to meet lowest achievable emission rates (LAER). This technology

determination does not allow the cost of a control device to be considered

in feasibility studies, making it a very stringent hurdle. Additionally, offsetsmust be purchased or obtained to ensure that emissions increases will not

adversely affect regional air quality. These permitting requirements arequite stringent and will continue to be applied in PM2.5nonattainmentareas. Monitoring and enforcement programs in the Northern Virginia

Regional Office (NRC) and VDEQ are strong. The NRC air compliance

and enforcement staff conducted 209 full compliance evaluations of

facilities, reviewed 55 stack tests, and conducted 96 Stage II inspections

in 2007. At total of 83 enforcement follow-ups were conducted in 2007 as

well. Additionally, in 2007, the northern Virginia Inspection and

Appendix K, Attachment 2 - Page Number:

7
(c) Comment: The attainment plan does not discuss additional RACT/RACM

in enough detail.

Response: 40 CFR 51.1010, which delineates requirements for

reasonably available control measures (RACM) and reasonably available

control technology (RACT), predicates the implementation of a suite of

measures on whether those measures can collectively advance the

attainment date of a nonattainment area by one year. Since the

metropolitan Washington area is currently attaining the 1997 PM2.5

NAAQS, based on FRM data for 2003-2005 and 2004-2006, it is not

possible for any suite of measures to advance attainment. This

explanation is provided in section 8.3 of the draft attainment plan. No

further requirements or discussions of RACT/RACM are necessary for the

plan to be approved. Therefore, VDEQ believes that RACT/RACMrequirements for this attainment plan are satisfied.

(d) Comment: U.S. EPA’s Clean Air Fine Particulate Implementation Rule

suggests the use of more stringent monitoring and opacity standards.

Virginia’s current opacity standard of 20% allows PM2.5emission increaseswithout adequate review. Opacity limitations should be strengthened to no

more than 10%.

Response: How the current opacity standard for large boilers allows

emissions increases above a baseline is unclear. However, the

justification for examining monitoring and opacity standards as discussed

in EPA’s Clean Air Fine Particulate Implementation Rule (72 FR 20586,

April 25, 2007) is that of RACT/RACM. The quote provided by the

commenter is found in 72 FR 20617 and is in the context of observationson control opportunities when examining requirements for RACT/RACM.

As noted in a previous paragraph, RACTIRACM requirements are

predicated on advancing the attainment date, which is not possible for the

metropolitan Washington area. Therefore, unless a facility undergoes amajor modification as part of the new source review major permitting

process, in which case LAER must be applied, or undergoes a minor

modification as part of 9 VAC 5 Chapter 80 Article 6 “Permits for New andModified Stationary Sources,” in which case state Best Available Control

Appendix K, Attachment 2 - Page Number:

8
error and bias do not provide assurance that the model predictions meet

the modeling performance goals on either a 24-hour or an annual basis.There is no observed error in model performance on the end model result

in the target year of 2010. The design value calculations should include

columns of maximum predicted values that reflect the model’s worst-caseperformance for this modeling domain. The analysis relies too heavily on

the trend in observed PM2.5levels.

Response: A critical component of every air quality modeling study is the

model performance evaluation (MPE) in which the modeled estimates for

the current year base case are compared against observed values to

assess the model’s accuracy and provide an indication of its reliability.

The first step in the modeling process is to verify the model’s performance

in terms of its ability to predict PM2.5and its individual components (i.e.,

sulfate, nitrate, ammonium, organic carbon, elemental carbon and other

PM25)in the right locations and at the right levels. To do this, the model

predictions for the base year simulation are compared to the ambient data

observed in the historical episode.

The MPE included in the metropolitan Washington attainment plan wasdeveloped based on input from several regional planning groups such as

the Mid-Atlantic/Northeast Visibility Union (MANE-VU), the OzoneTransport Commission (OTC) and the Association for Southeastern

Integrated Planning (ASIP). Specifically, all elements of the modeling

platform, including the emissions, meteorology, and air quality model,have undergone an evaluation.

The MPE consists of a combination of statistical and graphical evaluations

recommended by EPA in its guidance. After review of the MPE, if themodel appears to be producing PM2.5in the right locations for the rightreasons, then the model can be used as a predictive tool to evaluate

various control strategies and their effects on PM2.5

The issue of model performance goals for PM2.5is an area of ongoing

research and debate. Performance goals refer to targets that a wellperforming model should achieve, whereas performance benchmarks are

based on historical model performance measures for the best performing

Appendix K, Attachment 2 - Page Number:

9
y 

The results of the MPE for the metropolitan Washington area for PM2.5and

its individual species indicate that the CMAQ model performance forsurface PM25 is good, with acceptable bias and error. The MPE wasconsistent with EPA guidance and includes the proper statisticalperformance metrics.

EPA and VDEQ recognize that although good model performance remains

a prerequisite for use of a model in an attainment demonstration,

problems posed by less than ideal model performance on individual days

are reduced through the use of the model results in a relative sense.

Furthermore, starting with an observed concentration as the base value

reduces problems in interpreting model results. It is recognized that

model results and projections will continue to have associated uncertainty.

The attainment demonstration that EPA recommends recognizes this by

including modeling plus other supplemental analyses such as air quality

trends to determine whether all available evidence supports a conclusion

that a proposed emission reduction plan will suffice to meet the NAAQS.

In summary, VDEQ believes the issues identified by the commenter are

not regulatory requirements and are not appropriate for inclusion in the

attainment demonstration since attainment tests are based on theapplication of relative response factors. The regional and local model

performance is acceptable for PM25 and was evaluated using EPAapproved procedures. While there are some differences between thespatial data between sub-regions, there is nothing to suggest a tendency

for the model to respond in a systematically different manner between

regions. Examination of the statistical metrics by sub-region confirms the

absence of significant performance problems arising in one area but not inanother, building confidence that the CMAQ modeling system is operatingconsistently across the full modeling domain. This confidence in the

modeling results allows for the modeling system to be used to support the

PM2.5attainment plan.

(f) Comment: The proposed SIP provides no assurance that attainment with

the NAAQS will be achieved in unmonitored areas where local-scale

modeling is the only means for determining compliance. Alexandria is an

Appendix K, ttachment 2 - Page Number:

10
p

p

y 

compares all monitoring data to the 2006 daily 35 ug/m 3standard. Thisattainment plan is directed at the 1997 standards, for which the dailystandard is 65 ug/m 3.Data provided do not exceed 65 ug/m 3.

Additionally, Use of exceedence periods is not particularly helpful in

comparisons to the NAAQS. Each NAAQS standard contains both a

numerical limitation and a statistical methodology for computing that

standard from monitoring data. The statistical methodology, for examplean annual average or a fourth highest, three-year average, is partly due toconcerns of exposure time and rates. To violate a NAAQS, the standard

must be surpassed using the appropriate statistical approach. The Clean

Air Act (CAA) concerns itself with violations of the NAAQS, not

exceedences. Exceedences must therefore be considered data variability,

not actionable violations.

In regards to the inclusion of an unmonitored area analysis, the regional

modeling attainment demonstration does not address future air quality atlocations where there is no PM2.5monitor nearby. To guard against the

possibility that air quality levels could exceed the standard in areas with

limited monitoring, EPA suggests that additional review is necessary,

particularly in nonattainment areas where the PM2.5monitoring network

just meets or minimally exceeds the size of the network required to report

data to Air Quality System (AQS). This review is intended to ensure that a

SIP control strategy leads to reductions in PM2.5and its constituentpollutants at other locations that could have baseline (and future) design

values exceeding the NAAQS were a monitor deployed there. The test is

called an “Unmonitored Area Analysis” (UAA).

The UAA uses a combination of the 12-km gridded model output and

ambient data. The analysis should include, at a minimum, all nonattainment counties and counties surrounding the non-attainment area.

Based on VDEQ’s initial review of the gridded model output and ambient

data, the UAA is unlikely to reveal any areas where future design values

would exceed the NAAQS in the metropolitan Washington area.

EPA stresses that due to the lack of measured data, the examination of

concentrations as part of the UAA is more uncertain than the monitor

Appendix K, Attachment 2 - Page Number:

11
g 

NAAQS is being met at currently unmonitored locations. In fact, in many

ways the analysis of PRGS using special purpose monitors has already

fulfilled the goal of the UAA. VDEQ believes that the PRGS should not be

considered an “unmonitored area” based on the fact that there is a

continuous PM2.5monitor operating on the southeast property line and an

FRM located on the roof of Marina Towers. The Marina Towers FRM

monitor site is located in the area of expected maximum impact from

PRGS. PRGS remains one of the best monitored sources in Virginia.

Predicted violations of the UAA should be handled on a case-by-case

basis. As such, additional analyses and/or tracking requirements may be

needed depending on the nature of the problem and the uncertainty

associated with the potential violation(s). EPA also stated at its PM2.5

modeling workshop held on June 20-21, 2007, that the UAA was not

designed to look for unmonitored PM micro-scale hot-spot issues. This

would preclude the use of the UAA as a useful technique in evaluating

impacts from an individual source such as PRGS.

VDEQ is currently in the process of conducting the UAA for the

metropolitan Washington area. VDEQ is also part of the test group for

the recently released beta version of EPA’s “Model Attainment Test

Software (MATS)” which is the tool required to conduct the UAA.

Unfortunately, this tool is limited and does not have the spatial field feature

necessary to complete the UAA. EPA expects that this component will be

added in the next version of MATS and VDEQ will complete the analysis

upon release of the updated software.

The metropolitan Washington area currently has a network of 14 PM2.5

monitors. Several of these monitors were established as State and Local

Air Monitoring Stations (SLAMS). These SLAMS monitors were selected

based on specific monitoring objectives (background concentration, area

of highest concentration, high population, source impact, transport, and

rural impact) as required by EPA and siting scales (micro, middle,neighborhood, urban, and regional) established by EPA. It is believed that

the density of the monitoring network relieves the necessity of applying the

UAA. Despite being confident that the monitoring network is robust for the

metropolitan Washington area, once the final version of the MATS tool has

Appendix K, Attachment 2 -Page Number:

12
p

Q

p

VDEQ should immediately address primary impacts of PM2.5in the local

areas surrounding PROS. Modeling tools are available.

Resionse: VDEQ is examining the possibility of installing either a special

purpose PM2.5monitor or a PM2.5 FRM within Alexandria. Whether or not

such a monitor can be sited and operated within Alexandria depends on anumber of issues, including manpower and monetary resources as well as

locating an appropriate site for such a monitor. If at all possible, VDEQ

would prefer to gather necessary monitoring data to determine air qualitywithin Alexandria’s city limits. VDEQ is also exploring the possibility of

PRGS continuing to operate at least one of the two PM2.5monitoring

stations they currently are using to gather air quality data.

VDEQ disagrees that only through a modeling analysis can NAAQS

protection be assured. As stated in a previous paragraph, there are

several uses of air quality data in evaluating the impacts from a facilitysuch as the PRGS. One of the most important uses identified in the

EPA’s Guideline on Air Quality Models is the use of air quality

measurements “in a complementary manner to dispersion models with

due regard for the strength and weaknesses of both analysis techniques.”

While air quality measurements are particularly useful in assessing the

accuracy of model estimates, these measurements do not necessarilyeliminate the need to apply a model to assess an individual facility’s

impact. Although it is possible to use air quality measurements alone to

assess NAAQS compliance, this approach would not likely be preferred

unless available models are found to be unacceptable, and monitoring

data has sufficient spatial and temporal coverage.

Additionally, for certain pollutants, such as SO2,conservative EPAapproved modeling analyses. are indeed available and can be used for

such a purpose. However, this is not the case for all pollutants. Forexample, there is no source specific, EPA-approved modeling approach

for ozone from facilities that emit VOC and NOx. VDEQ disagrees that

appropriate modeling methodologies exist for estimating direct PM2.5

impacts. A few states have published guidance for estimating impacts

from new or modified sources using state-specific significant impact levels.

No federal guidance has yet been finalized on such protocols. Currently,

Appendix K, Attachment 2 - Page Number:

13
pCommonwealth. Use of such guidance, as applied to existing facilities,

may unjustifiably require source curtailment or other expensive operational

changes to meet air quality standards and protect public health.

Section 9.4.3 requires an analysis be performed after an analyticalapproach is finalized by EPA and peer reviewed. This analysis may or

may not involve Gaussian modeling of some type. Regardless, the

analysis will be performed to ensure PM2.5NAAQS compliance by PRGS.

(h) Comment: In Section 9.4.3, VDEQ defers any modeling analysis of the

PRGS facility until an appropriate implementation methodology for PM2.5is

established, which appears to be an acknowledgement that the proposedSIP is deficient and that a more appropriate implementation plan is

necessary.

Response: Section 9.4.3 was in no way added to the attainment plan to

address any “deficiency” of that plan. Section 9.4.3 was included to

address Alexandria’s concerns regarding PM2.5air quality even though thespecial purpose monitors in the City do not show violations of either the

1996 or the 2006 PM2.5NAAQS standard. VDEQ believes that including

such requirements to address concerns is an appropriate use of the

attainment plan. However, it is not a requirement of the PM2.5planning

process to address any particular facility, and the plan would be complete

and approvable without this language. Generally, VDEQ believes that

such facility concerns should be addressed within the normal VDEQpermitting processes. In this case, the language in Section 9.4.3, much of

which is also includ.ed in the recent draft permit for PRGS, was added to

V

the draft attainment plan in part to help build a consensus with

Alexandria’s participants in the planning process and to help provide

assurances to the citizens that air quality it being protected.

(i) Comment: Alexandria strongly recommends that a local area analysis

(LAA) be conducted.

Response: The LAA uses dispersion models to address observed primary

PM2.5contributions at monitors. Specifically, in areas with large spatial

gradients of primary PM2.5,dispersion models are best suited to

Appendix K, Attachment 2 - Page Number:

14
q

p

photochemical grid modeling, the dispersion model results should be

compared to ambient data to ensure that the model is working well. Many

of the same statistical calculations used for photochemical grid modeling

are recommended for evaluating primary PM2.5and PM2.5componentspredicted by a dispersion model.

The LAA is used to determine the actual (or typical) contribution from

sources at a monitor, and the model results are used in a relative sense.

Therefore, it is only appropriate (and in fact conservative) to use actual

emissions in the base year and projection year emissions inventories.

Using actual emissions should lead to a reasonable estimate of air quality

improvements from reducing emissions at the contributing sources. Using

allowable emissions might lead to an overestimate of benefits fromemissions controls.

The LAA appears to be an optional element of the SIP modeling

demonstration, and the need for this analysis is considered on a case-bycase basis. The LAA is likely not required by EPA as part of the

metropolitan Washington attainment planning process. This is due to the

fact that the monitoring network does not have any observed spatialgradients of primary PM2.5and that the attainment plan does not need to

rely on local primary PM2.5controls to reach attainment.

Based on its review of existing monitoring data, EPA initially did not invite

VDEQ to participate in a LAA workshop that was conducted in Chicago on

October 17-18, 2007. However, due to concerns expressed by

stakeholders, VDEQ requested and was granted approval by EPA toattend this workshop. The focus of the workshop centered on areas that

have elevated primary PM2.5concentrations in their core urban areas or

that contribute to their highest FRM. The table below provides a list of the

areas in the Eastern United States identified by EPA for a LAA:

Appendix K, Attachment 2 - Page Number

15
g

pg

, 

Pittsburgh, PA

Areas with 2004-2006 annual DV greater than

3 Atlanta GA 17 pc/rn and 24-hour DV greater than 35 Indianapolis, IN pg/rn

Areas with 2004-2006 annual DV greater than Chicago, IL

15.5 pg/rn 3and 24-hour DV greater than 40 Steubenville, OHpg/rn 3. New York, NY

Baltimore, MDCharleston, WV

Huntington/Ashland, WV/KY/OH

Areas with 2004-2006 annual DV greater than Lancaster, PA

16.0 pg/rn 3. York, PA

Louisville, KY

Macon, GASt._Louis,_MO

At this time, no monitors within the metropolitan Washington area are

projected to exceed the NAAQS so it does not appear to be a necessary

requirement in this circumstance to conduct the LAA. All of the regionalmonitors are projected to reach attainment with the PM2.5NAAQS in 2009.

The future year inventory projections have significant decreases in

primary PM2.5and PM2.5precursors resulting from various controlprograms throughout the region. Furthermore, existing monitoring data

suggest a uniform regional pattern with respect to PM2.5concentrations.No monitor’s data appears significantly different, on average, than data

• gathered at other monitors within the FRM network. For these reasons,

VDEQ does not believe that a local area analysis is necessary.

(j) Comment: VDEQ’s proposed permit for PRGS is contradictory to SIP

goals. The inventory used in the attainment plan regional modelingexercise is less than proposed permit limits and therefore underestimatesemissions.

Resjonse: VDEQ disagrees that the proposed permit is contradictory to

SIP goals. The goal of the attainment plan is to demonstrate complianceby 2009 with the 1997 PM2.5NAAQS standards. Current FRM data show,

as discussed in other responses, that the region is indeed meeting the

1997 PM25 NAAQS standards. The proposed PRGS permit reduces

emissions from the baseline year for this facility. VDEQ believes that the

Appendix K, Attachment 2 - Page Number:

16
Modeling performed within the PSD permitting program to determine if a

facility causes or contributes to a NAAQS violation is performed whenguidance for such analyses is available. Additionally, such analyses aretypically performed at the facility’s potential to emit or permitted levels to

ensure that all levels of operation by the facility will not impact the

NAAQS.

Regional modeling inventories are based on actual emissions and

projected emissions, partly due to the fact that the model is regional innature. Projected àmissions are rarely, if ever, as high as the potential to

emit of a facility. To assume that projected emissions equal potential toemit for every facility in the point source inventory over an entire region

would drastically inflate emission estimates in the projection year,

especially considering the conservative nature of the other projectionestimates. For instance, the emission factors for area source categories

are generally highly conservative. These estimates are further inflatedsince many are grown in relation to population increases, which in the

northern Virginia area are quite high. Additionally, transportation budgetsin the projection year do not take into account transportation emissionreduction measures (TERMS), which account for many tons of emissionreductions and are withheld for use in rare conformity situations.

Transportation emissions also do not take into account emission

reductions achieved through VDEQ’s On-Road Emissions Testingprogram, which monitors the tailpipe emissions of vehicles to locate andrepair polluting automobiles between required station inspections. For

these reasons, and many others, VDEQ believes that the 2009 projection

year inventory is quite conservative. As noted in paragraph (b), drasticover inflation of the projected point source emissions inventory may have

the effect of requiring costly and likely unnecessary regional control

measure implementation. Such mitigation efforts cannot be supported if

there is every reasonable expectation that PM2.5air quality is good and

getting better, as indicated by the FRM data. Therefore, VDEQ does not

support the approach of setting projection year emission inventories equal

to permitted limits or potential to emit.

(k) Comment: The SIP does not address the reduced operational loads of

PRGS that were important events in relation to the downward 24-hour

Appendix K, Attachment 2 -Page Number:

17
p

Q 

g

facility’s operational changes between 2002 and 2009 are necessary. The

goal of the attainment plan is to demonstrate compliance with the 1997

PM25 NAAQS by 2009 on a regional basis. The attainment plan

discusses the enforceable limits of the Virginia CAIR Caps, to which

PRGS is subject, on Page 5-3, as well as a variety of other control

measures and their expected overarching effect on air quality, such as the

Maryland Healthy Air Act and a coal-to-natural gas conversion made at a

nearby power plant. None of these descriptions include greatly detailed

accounts of each measure or strategy since the sum total of all the

reductions are used to show that PM2.5regional air quality in northern

Virginia and metropolitan Washington is good and getting better.

Additionally, providing in Chapter 9 a discussion of various control strategy

and programs implementation schedules as they correspond to FRM

monitoring results would be an incredibly lengthy process, given the

number and variety of control programs that have gone into or arescheduled to go into effect between 2002 and 2009. Such an analysis

would have to include reductions from such significant source sectors as

the power industry, the transportation sector, the petroleum fuel sector,

auto body refinishing, surface coating, and many others. Such an analysis

is unnecessary in any event due to the regional context of the attainment

plan.

(I) Comment: VDEQ should not rely on PM10 as a surrogate for PM2.5in the

permitting process for PRGS. EPA has suggested, in May 31, 2006,

correspondence from Mr. Donald Welsh to Congressman James Moran

that the PM2.5SIP is an appropriate place to address the issue of PRGS’

air quality issues.

Response: VDEQ does not believe that the PM2.5attainment plan is an

appropriate arena in which to discuss federal permitting guidance,adopted by VDEQ, in regards to the use of PM10 as a surrogate for PM25.

Such permitting concerns are more appropriately addressed through the

many significant public participation opportunities afforded the public

during the permitting process. In any event, VDEQ believes that the

current permitting guidance is appropriate since it reflects the suggested

federal guidance on the issue of PM2.5in permits.

Appendix K, Attachment 2 - Page Number:

18
g

, 

p

g 

emissions, or a specific PM2.5permit limit given to the PRGS through the

normal Virginia permitting process. A permit limit for PM2.5 is the mostlikely mechanism; however, at present Mirant is not subject to any suchpermit limits.”PRGS air quality issues are being addressed through VDEQ’s normalpermitting process. Requirements of the permit and of the draft

attainment plan as listed in Section 9.4.3 mandate an ambient air qualityanalysis after methodologies for such analyses are finalized. VDEQbelieves that use of the normal permitting process is appropriate for

addressing specific facility concerns.

(m) Comment: Language in Section 9.4.3 requiring an ambient air quality

analysis is deficient since it fails to insure that the analysis will be done ina timely manner. It also suggests that methodology to conduct such an

analysis is not available at the present time, which is contrary to existing

EPA guidance. The language should be revised to read:

Using an available Gaussian dispersion model, such as AEROMODY for

stationary sources, which has been approved by USEPA to model primaryPM2.5impacts, VDEQ shall conduct an ambient air quality analysis of theemissions of PM2.5from the Mirant Potomac River Power Generatingfacility. VDEQ shall complete this analysis within 120 days of adoption of

the SIP by MWAQC.

Resronse: VDEQ does not believe the language suggested by the

commenter is appropriate. As noted in previous paragraphs, it is notcertain that Gaussian dispersion modeling will be a requirement of PM2.5ambient air quality analyses. EPA has not yet published modeling

guidance for PM2.5pollution. Use of published guidance for other

pollutants, such as SO2,is not prudent given that the highly complexnature of PM2.5chemistry may not make the use of guidance for otherpollutants applicable. If Gaussian dispersion modeling is eventuallyrequired, no federal guidance currently exists explaining the application to

PM2.5of this technique, which is multi-faceted and highly complicated.

Appendix K, Attachment 2 - Page Number:

19
could have possible significant adverse health and/or environmental

impacts. This approach goes beyond that of other States that have•

developed procedures that evaluate new and modified facilities only.

VDEQ is seeking membership from environmental and health

organizations, academia, the legal profession, and industry or tradeassociations that have a background in air quality modeling, policies, or

programs to serve on this workgroup. The first meeting will likely takeplace in March of 2008. Due to the exploratory and controversial nature of

this workgroup, no estimation of the time frame for workgroup product

completion and approval by the SAPCB can be made. However, VDEQ

will be providing the SAPCB periodic updates on the progress of the

workgroup’s efforts.

The language included in Section 9.4.3 states that the timeline for

submitting the analysis will be determined by VDEQ management. This

language was included to account for the fact that the requirements of theambient air quality methodology are not known so that a reasonable

timeframe cannot currently be fixed. However, it is reasonable for VDEQ

to require that PRGS submit a protocol once the final methodologies are

approved by the SAPCB within a certain time frame, for instance 60 days.

VDEQ will also commit to publishing this document on the VDEQ website

so that citizens may review the contents. Section 9.4.3 has been updated

to reflect this change and now reads:

Based on a schedule and protocol to be established by VDEQ after US

EPA promulgates final rules for PM2.5analysis, or UE EPA promulgates

revised implantation guidance or policy for PM2.5 analysis, or VDEQ

establishes a more appropriate implementation methodology for PM2.5,

Mirant Potomac River Power Station shall conduct an ambient air qualityanalysis for the emissions of PM2.5 from the facility. No later than 60days after approval of the implementation methodology by the Virginia

State Air Pollution Control Board, Mirant Potomac River Power Station

shall provide to VDEQ a detailed protocol outlining how the facility willimplement the approved methodologies. VDEQ will make this document

available to the public by publishing this protocol on the VDEQ website.

Appendix K, Attachment 2 -Page Number:

20
p

y 

y 

part of the supplemental analysis.

COMMENTER: Mr. William J. Skrabak, Chief, Division of Environmental Quality,Department of Transportation and Environmental Services, City of Alexandria on

behalf of the City of Alexandria.

TEXT: The full text of this submittal, dated January 30, 2008, is attached to this

document. Alexandria is requesting the inclusion of various measures that thecity funds and oversees in the attainment plan, as these measures are

directionally correct and improve air quality.

RESPONSE: VDEQ has added the supplemental measures as listed by the

commenter into the draft attainment plan.

4. SUBJECT: PRGS impacts on PM2.5concentrations in the City of Alexandria

COMMENTER: Mr. C. Flint Webb, P.E., Environmental Committee Chair,

Fairfax County Federation of Citizen’s Associations

TEXT: The full text of Mr. Webb’s comments, submitted January 29, 2008, isattached to this document. The commenter requests that the Community Multiscale Air Quality (CMAQ) model be re-run to calculate a design value for a model

node point representative of downtown Alexandria.

RESPONSE: VDEQ cannot use the CMAQ modeling results as indicated by Mr.

Webb and still conform to EPA guidance on how CMAQ results should be used.As noted in various other responses, EPA recommends the use of CMAQ results

in a relative sense when calculating future design values. In other words, CMAQ

is run for both 2002 and 2009, and estimated concentrations for PM2.5for each

year are used to create a ratio. This ratio may be thought of as 2009 divided by

2002; however, this explanation is somewhat oversimplified since PM2.5is a

composite of a variety of different chemical compounds that must be factored into

the equation. The calculated ratio of 2009 to 2002 is then applied to actual 2002

monitored design values at FRMs to calculate the projected 2009 design values

for each monitoring site. EPA recommends the use of CMAQ in this manner for

many reasons. One reason such methodology is recommended is the state of

Appendix K, Attachment 2 - Page Number:

21
g

p

j

g 

Since no FRM monitor exists in Alexandria, this modeling exercise cannot be

performed according to EPA guidance. Please note that in other response to

comments, VDEQ states that consideration is being given to locating either a

special purpose PM2.5monitor or a PM2.5 FRM in the City.

5. SUBJECT: PRGS impacts on PM2.5concentrations in the City of Alexandria

COMMENTER: Mr. C. Flint Webb, P.E., Environmental Committee Chair,Fairfax County Federation of Citizen’s Associations

TEXT: The full text of Mr. Webb’s comments, submitted January 29, 2008, isattached to this document. The commenter recommends that the attainment plan

should include a Gaussian dispersion model for PRGS of direct fine particulate

emissions with downwash. He suggests that data from the model should not be

added to background concentrations to address the issue that backgroundconcentrations may include the effects of PRGS’s emissions.

RESPONSE: VDEQ believes that specific facility concerns, including results of

any air quality analysis performed on PRGS or any other facility, do not belong in

a regional attainment plan. Due to significant facility concerns, Section 9.4.3,

which reiterates the requirement in the draft permit for PRGS, requires an

ambient air quality analysis be performed on PRGS’s emissions when

methodology for such an analysis is finalized. Including the results of the

Gaussian dispersion model performed by the City of Alexandria on this facility as

part of the attainment plan would not make the plan any more approvable.

VDEQ believes the draft attainment plan is fully approvable in its current state.

Including the results of the Gaussian dispersion model may also be premature

since it is unclear what methodology will be recommended for PM2.5ambient air

quality analyses. If the recommended methodology is something otherthan a

Gaussian dispersion model, including the results of such modeling in the

attainment plan could be misleading. Lastly, it is unclear what purpose including

the results of Alexandria’s Gaussian dispersion model with the background

concentration removed would serve. The table below shows Alexandria’scalculated impacts by PRGS in the Gaussian model. Not including the

background concentrations would demonstrate a maximum impact of 8.2 ug/m 3

Appendix K, Attachment 2 - Page Number: 22
(Case ID - 5 units operating at mid-range !oaci for 24 hours oer day)

24-hour Annual

(pglm 3) (pglm 3)

Stack Impacts on Elevated Receptors: 6.5 0.9

3-year avg. of 8thhighest, stacks alone, among all

Marina Towers rooftop receptors.

Coal and Ash Yard Impacts on Ground-level 8.2 2.6

Receptors:

3-year avg. of 8th.highest, ground-level, from coal andash yard sources only.

Background 34.1 14.1

3-year avg. of 8tIhighest, closest monitor.

NAAQS 35 15.0

6. SUBJECT: Various recommendations on clarifying text, providing technical

details, and growth rates for area source emissions inventories.

COMMENTER: Mr. C. Flint Webb, P.E., Environmental Committee Chair,

Fairfax County Federation of Citizen’s Associations

TEXT: The full text of Mr. Webb’s comments, submitted January 29, 2008, is

attached to this document. The following paragraphs list the various

recommendations made.

(a) Comment: Figure 2-5 d9es not include data for March through September

of 2005.

Response: This figure has been updated to include information through

December of 2005.

(b) Comment: Text in Section 2.2.4 does not appear to support the figure.

Perhaps different plots should be used.Response: An updated figure and additional information within the text of

the section have been added.

(c) Comment: Figure 2-10 needs more explanation, especially concerning the

reasons for not considering ammonia emissions for control purposes in

the SIP. Also, terms on the figure need more explanation.

Appendix K, Attachment 2 - Page Number:

23
(d) Comment: Figure 2-1 1 is misleading. The axis should be changed to

reflect zero orshould contain a jog to indicate that the axis doesn’t begin

at zero.

Resronse: The range of the y axis in Figure 2-11 was defined from 14.0

to 17.5 in order to clearly demonstrate a declining design value trend line.

Extending the y axis to zero instead of 14.0 creates a trend line that is

nearly flat. A flat trend line does not clearly indicate the significant level of

air quality improvement measured by the FRM network. Also, data arelabeled for design values for different years, and the annual PM2.5standard line is clearly delineated in the graph. VDEQ disagrees with the

commenter and believes that the figure is quite clear in its meaning.

(e) Comment: The plan needs to clarify the difference between area “non

stationary” sources and mobile sources. A definition for “countyequivalent” should be provided. Non-road airport vehicles need to bementioned in Section 3.2.2.

Response: A sentence has been added to Section 3.2.3 to define what

constitutes a mobile source. Section 3.2.2 provides details about areasources, and the discussions in these two sections make clear distinctions

between area and mobile sources. Examples have been added in Section

3.2.2 to illustrate the differences between area “non stationary” and mobilesources. Since the MWAQC area inventory is calculated at county level,

the term “county-equivalent” is not relevant and has been deleted. Nonroad airport vehicles are included in the non-road inventory.

(f) Comment: The commenter suggests examining certain sectors of the

area source emissions inventory to determine if appropriate growth factors

have been used. The specific sectors mentioned are residential fuel

combustion, open burning, municipal landfills and incineration, and fugitive

dust emissions.

Response: VDEQ has examined the open burning emissions category

and found updated guidance for determining emissions from this source

sector. See the comment on this subject submitted by VDEQ. However,

for the other mentioned sectors, growth surrogates for different area and

Appendix K, Attachment 2 -Page Number:

24
examined for use in future inventories.

7. SUBJECT: Health effects of PM25.

COMMENTER: Mrs. Julie Crenshaw-Van Fleet, citizen of the City of Alexandriaand member of the Air Quality Public Advisory Committee (AQPAC)

TEXT: The full text of Mrs. Crenshaw-Van Fleet’s comments is attached to this

document. The following bullets summarize these comments and questions

regarding health effects.

• The attainment plan makes no mention that the reductions, contingencies, or

controls as documented will cause a reduction in the occurrences of the healthconditions and problems caused by PM25.

• Will health problems and conditions associated by the Department of Energy with

PRGS in its SEA decrease with the application of this attainment plan?

• Results from a study done by the Agency for Toxic Substances and Disease

Registry are due sometime in late winter or early spring of 2008. This study

should be carefully reviewed.

Response:Language has been added to the attainment plan to indicate that attainment of

the PM2.5NAAQS, as well as further air quality improvements, will have a positive

influence on the health and well-being of the citizens of the Commonwealth.

The attainment plan requires that PRGS perform an ambient air quality analysis

when the methodology for such an analysis is finalized. The results of this study

may show that additional controls on PRGS are needed to ensure the PM2.5

NAAQS is met. The purpose of the attainment demonstration is to ensure that

the region meets the NAAQS in a timely manner. The plan also ensures thatfurther air quality improvements will be enjoyed by the citizens of the

metropolitan Washington area. However, the CAA does not mandate that a

study demonstrating health benefits from each control program as applied withineach separate nonattainment area be provided to create an approvable plan.

While such information would certainly be interesting and noteworthy, VDEQ

Appendix K, Attachment 2 - Page Number:

25
8. SUBJECT: PM2.5monitors located near large PM2.5sources

COMMENTER: Mrs. Julie Crenshaw-Van Fleet, citizen of the City of Alexandria

and member of the Air Quality Public Advisory Committee (AQPAC)

TEXT: The full text of Mrs. Crenshaw-Van Fleet’s comments is attached to this

document. The following bullets summarize these comments and questions

regarding health effects.

• Current PM2.5monitors at PRGS do not meet siting criteria and thus cannot be

used for this SIP.

• Are there other point sources in the Metropolitan Washington Region that would

benefit from properly sited PM2.5monitors? Any and all locations that are

considered sources of PM2.5emissions should have PM2.5monitors properly sited

under EPA criteria.

Response: One monitor located near PRGS, the monitor sited on top of the

Marina Towers, uses federal reference measurement methods to collect data on

that site. The location does not meet the criteria for FRM monitoring sites since

FRM siting criteria include limitations on the height of the sampling probe. The

criteria suggest that appropriate heights for probes should be approximately

equal to the level at which an average person breathes.

However, data from this site have not been discounted. Since the FRM testing

methodology requires the use of a laboratory to analyze filters, FRMs are not real

time monitors. In other words, there is a lag between the sample collection time

and when the results of the laboratory analyses are received. For the FRM on

the top of Marina Towers, at the time the draft SIP was being written, VDEQ had

10 months of 2007 data, January through October. To calculate an annual

average, 12 months of data are needed. As a place holder, data from November

and December of 2006 were used to examine the annual average at that

monitoring site. The data indicate an annual average for one year of 13.7 uglm 3,

well below 15.0 ug/m 3.This information was not included in the draft attainment

plan because using November 2006 through October 2007 data is an irregularmethod of calculating an annual average; because three years of data were not

available from this monitoring site, as required by the statistical methodology for

the NAAQS; and because the calculated annual average was well beneath the

• Appendix K, Attachment 2 - Page Number:

26
p

Q 

g 

g

a PM2.5monitor within the City of Alexandria due to concerns raised about the

Mirant Potomac River Generating Station. For a number of reasons, however, it

is impractical to locate PM25 FRMs near every source, or even every major point

source, of PM2.5emissions in the metropolitan Washington area. First, PM2.5

FRMs are resource intensive. Installing a PM2.5 FRM costs approximately

$13,000 each. Annual operations for each PM2.5 FRM cost approximately$15,000. VDEQ must operate within its resource constraints. Adding additional

monitors to the already robust monitoring network in metropolitan Washington

would be quite costly. Another reason such a plan is impractical is the fact that

additional monitors may likely show no great deviation from the measurements

made at the current FRM sites. To date, the FRMs in the metropolitan

Washington area do not appear to show a great deal of data deviation, indicating

that the PM2.5air quality in the metropolitan Washington area is more a regional

issue than it is a localized issue. VDEQ does not believe it necessary or costeffective to locate FRM’s near every major point source of PM2.5emissions in the

metropolitan Washington area.

9. SUBJECT: Emissions from PRGS.

COMMENTER: Mrs. Julie Crenshaw-Van Fleet, citizen of the City of Alexandria

and member of the Air Quality Public Advisory Committee (AQPAC)

TEXT: The full text of Mrs. Crenshaw-Van Fleet’s comments is attached to thisdocument. The following bullets summarize the comments concerning PRGS’s

emissions.

• Mirant Potomac River Generating Station is a point source considered to be a

high polluter by EPA. High polluters should be considered hot spot problemlocations.

• The use of TRONA at PRGS, and its effects on PM2.5emissions and human

health, should be discussed in the attainment plan.RESPONSE: EPA does not define a “hot spot” within regional modeling

guidance. The current EPA guidance for regional modeling to support attainment

plans notes that LAA’s are required for areas within a region that show elevated

monitored PM25 concentrations at monitors within the federal reference

Appendix K, Attachment 2 -Page Number:

27
NAAQS. Additionally, FRM monitoring data at the nearby monitoring station in

Arlington show compliance with the NAAQS. Regardless, the attainment plan

does include requirements for further actions to address the concerns regarding

emissions from PRGS through additional analyses, when methodologies becomeavailable, as required by Section 9.4.3.

The commenter expressed concern about the use of TRONA injection for SO2

control at the PRGS and the need for effects of TRONA injection to be

documented in the attainment plan. VDEQ does not believe the attainment plan

is an appropriate place to enumerate details about a specific facility’s operational

considerations. Such details are routinely examined and incorporated into

permits through the normal VDEQ permitting process. Such details have been

and continue to be the subject of scrutiny by the NRC permitting staff in the

ongoing PRGS permitting process. The PRGS permitting process has

incorporated many public comment opportunities to provide citizens the

opportunity to examine and make comments on the drafts.

In regards to specific concerns about PM2.5increases from the use of TRONA

injection at PRGS, an attachment to this document goes into great detail about

that very issue. The May 31, 2006, letter from Mr. David Welsh to Congressman

Moran provides an enclosure that addresses the issues of full scale evaluations

of TRONA use and particulate increases due to TRONA injection. The enclosure

states, “EPA believes there is sufficient evidence that TRONA is a suitableabsorbent for injection into a power plant flue gas stream for the purpose ofremoving sulfur dioxide. ... The Material Safety Data Sheet (MSDS) for TRONA

identifies is as a relatively non-toxic compound. . . .“ The enclosure also

summarizes the effect of TRONA at PRGS as, “TRONA was demonstrated to

remove 80% of SO2emissions, while not impacting opacity and significantly

decreasing the PM10 emission rate.”

PM2.5tests were performed using EPA’s Conditional Test Method 40 (CTM-40) atPRGS on December 14 through 17, 2006. These tests confirmed that TRONA

injection did not increase PM2.5emissions from the boilers.

Appendix K, Attachment 2 - Page Number:

28
document. The following bullets summarize the comments concerning PRGS’semissions.

• PRGS is the single largest source of PM2.5in northern Virginia.• PM25 monitors at Marina Towers measured concentrations above the 35 ug/m 3

24-hour NAAQS on several occasions in 2007.

• EPA scientists have recommended an annual PM25 NAAQS limit that is lower

than 15.0 ug/m 3.

• The City of Alexandria’s dispersion modeling to date, including downwash,

demonstrates that a “hot spot” exists.

• PRGS contributes significantly to PM2.5nonattainment in Alexandria and the

metropolitan Washington areas.

RESPONSE: VDEQ agrees that PRGS is a large emitter of PM2.5 However, it is

not the largest point source emitter in the metropolitan Washington area, nor is it

the largest emitter in northern Virginia, when all segments of the point, area, nonroad, and transportation inventories are considered.

As stated in other portions of this document, short-term excursions above the 35

uglm 3standard are not actionable violations. Violations are based on statistical

methodologies to take into account exposure rates. Occasional exceedences of

the 35 ug/m 3standard must be treated as data variability unless a violation of the

PM25 NAAQS occurs. Additionally, this attainment plan is designed to address

the 1997 PM2.5NAAQS, which sets the standards at 15.0 ug/m on an annual

average and 65 ug/m 3on a 24-hour average. Since the NAAQS standard is

based on three years of data, only a partial evaluation can be made of the Marina

Towers monitoring data. As noted in other places within this document, forJanuary through December of 2007, the Marina Towers monitor measured an

annual average of 13.5 ug/m 3and a 24-hour average of 31.3 ug/m 3.VDEQ willcontinue to examine the data gathered from this monitoring site.

The purpose of this attainment plan is to address the 1997 standards as

finalized. These standards are 15.0 ug/m 3on an annual average and 65 ug/m 3

on a 24-hour average. Certainly it is important for VDEQ to be mindful of the

2006 standard revision to 35 ug/rn 3on a 24-hour basis as well as other

information such as scientific recommendations. However, this document, whichshows that air quality has improved and currently meets the 1997 standards at all

Appendix K, Attachment 2 - Page Number:

29
monitoring network when compared to data from other federal reference monitors

in the region. EPA does not, within the context of SIP attainment planning, have

a definition for the term “hot spot.” The monitoring network shows similar results

for various monitoring sites.

To ensure that PRGS is not causing a NAAQS violation, VDEQ has included a

requirement in the attainment demonstration that an ambient air quality analysis

of PRGS emissions be provided once such methodology is finalized. The City of

Alexandria’s modeling exercise of PRGS’s emissions does not use a

methodology that has been peer reviewed and finalized by EPA. Themethodology may double count PRGS emissions since it adds background

concentrations from nearby PM2.5 FRMs even though PRGS, as an existing

facility, contributes to these concentrations. The methodology adopted by

Alexandria has been used by other states, but only for new and modified

sources, not existing sources. These reasons, and others, make Alexandria’s

methodology and results inappropriate for inclusion in this attainment

demonstration.

11. SUBJECT: Non-road emissions.

COMMENTER: Mr. J. Charles Baummer, Jr., Environmental Engineer, Office of

Engineering, Metropolitan Washington Airports Authority

TEXT: The full text of Mr. Baummer’s comments is attached to this document.

The commenter requests confirmation that the attainment plan intends to account

for airport construction equipment emissions. Additionally, the commenter

requests that construction emission budgets for airports can be derived from theplan as percentages of county construction equipment emissions, based on

employment at the airports relative to county employment.

RESPONSE: County level construction emissions are intended to account for

construction emissions at the airports as well as other facilities within eachcounty. VDEQ agrees that past methodologies have used a percentage ofemployment by the airport, as compared to county employment data, todemonstrate the inclusion of these emissions in the implementation plan.

However, VDEQ does not believe it is appropriate to include this methodology in

Appendix K, Attachment 2 - Page Number:

30
yp

g

p

COMMENTER: Ms. Marilyn Powers, EPA Region Ill

TEXT: The full text of Ms. Powers’ comments is attached to this document. Thecommenter notes that the plan must address both the annual and 24-hour 1997

NAAQS standards; that much of the guidance for this plan is also relevant to both

the annual and 24-hour standard; that the appropriate level of precision for the

annual standard is 15.0 ug/m 3;that clarifying language in regards to the status of

the nonattainment area emissions caps within the VA CAIR rule should be

added; and that a typographical mistake was located in Section 9.3.1.

RESPONSE: Based on EPA comments, modifications have been made to text

in Chapters 1 through 4, and appendices B, D, and El to reflect the fact that the

plan addresses the 24-hour PM2.5standard as well as the annual standard; toreflect the appropriate level of significant figures in standards; to clarify the status

of the VA CAIR rule and associated nonattainment area emission caps; and to

correct typographical errors.

13. SUBJECT: PM2.5area source emissions from open burning-land clearing

COMMENTER: Mr. Thomas Ballou, Director of Air Data Analysis and Planning,

VDEQ (The comment was supplied to MD and DC, but included here for

completeness.)

TEXT: The full text of Mr. BaIIou’s comment is attached to this document. The

commenter requests that the northern Virginia area source emissions inventory

be corrected for years 2002 and 2009 and that all charts and references to thesenumbers be updated.

RESPONSE: Appendices B, Cl, and D have been updated to reflect 2002 and

2009 PM2.5and PM10 emissions changes. Chapters 1, 3, and 4 have beenedited to reflect the revised numbers for these pollutants in Northern Virginia.

Appendix K, Attachment 2 -Page Number:

31
GOVERNMENT OF THE DISTRICT OF COLUMBIA

Department of the Environment

V Environmental Protection Administration

Air Quality Division

FEBRUARY 11,2008 

Public Hearing on Draft State Implementation Plan 

For Fine Particle (PM2.5) Standard and 2002 Base Year Inventory 

Please sign in below:

NAME AFFILIATION (if any) ADDRESS

.

$S1’c aW 

2.

LLC

______

1 C 

6.

7. 1 S- 

8. w(I 

9.

10.
L..

1

• •-,
,

CARL S. J.QHNS} who is being duly sworn according to law, an oath says that he is an AUTHORIZED AGENT of THE WASHINGTON TIMES, L.LC., publisher of

Ciiculated daily, in the City ofWashington, District of Columbia, and that the advertisement, ofwhich the annexed is a true copy was published in said newspaperj.. time(s) on the following dates:

ZQ4)8_JANUARY.i j 00V!RNMDIT OF ThE QISI1ICT GOWUSIA .

OW A QUAUTV IS5SJ

Nelke k letciby glcee ;Iiee a Wib(e hearlm will ilp fillS CII bloeday. Cilb,IlU, it 2001c1 0:01, fIjil. III tile Cdl FIo, oon#r eIICn roonc,1I 5) N l,eaa. III, b01tWlwFCll. O.C. This fleadn preolCes IIIleiCuted parllss Ii, 0p551 luiliCI 15 Cilmmllt mi lee at the rate of $2.91 Per line

Tile OreSceid S1,le emere.tlii P!i,n (SIP) far Apeowl lIne eve fae (PM2!) SISISVd end aat ease eee 5NeMOl lee tej WIIIngtQft OGMilVA $00 tOllwnm A,—; combs 01(I) a deaerfatlocoaoxisenpcopflel Ilmedoillo- (III an almimNeip o1ll- ,,aasly 1,vabIbblt Ctnirl fl$Il0l. (III) reeler cuticle cmli. Total Cost $ 331.74 Dollars

pliltil ceezalea lire beec acm Sic P01101W CISISCIAm leneliluly had o .Oi9 pm(eottd lIwontoly. wihlCq 101141 10 SIC IlIjIS Feral Sleonina eeOvhFlc$ meiqeed 15 tee Cuand

‘,

The ate oSed SIP aime precates File Dietrict And the U

-

A

OSteto bIble PeIda 10 IPFPIV14 alr QUAlIFY In Foe wsSfIilFIisn nCL,lteIpment InCA AM Inc *lirl I hStu Ia mre Cecelcaly Inc (CCCII 10150cC, tIre 015cm’ ‘realSi Ilild Subscribed and sworn to before me 42.5 UWAC crepomef enmp wl

lelIon em me 1q91 PMI... S100SIIFAI. On Occember IT, Q7. MWAQC noulered tOp prepsoed Wa”, AnA DC ‘ad e elites arr.mIe9ftotatIIc 11n10w3n510111M001. JA.NIJ.A..RY’ II. 2008 1110 DiCpesei 5IP reololoc, are Ynalebic tot peASe rprlew Cal In9 riewlial beII14eS hAute ‘n 51 oIIICII Al the DiStrict Dipot. 1,01St of tuG EltelPonhlleel WuusImInQaen. (DDOEJ. SI II SeleCt. NE. POem PONt D.C. 20102: III UCIFOSAISAn heehinuepo CQncII no Oov.rnrmi0C{b SuIte 100 17? loriS CepiFol Sheds. Wash. It- 4f j/ j3jjJ•

Notary Public N’ —. L1LC/bWE9

InOfeIted 1pAr1Ies wInMi’g to tegilly ii ISle Iievl,iQ elliOt Cub ITt F II’ 31,11119 theIr eamee, adainclee. IlleSfidSe numoele flop alhulAtlon. II any to UP. CP$L5I filoctor ii 0OO fZNU42I7) 00 410 Pin.. tehnary SI. 1108. ND P411CC crellowni a’te be 1øL) 14. MbiItton

t4ctiry Public, District 0? Columbia ‘ -.

My CammlIon ExpIres 6-14-2010

My Commission expires

AUTHORIZED AGENT of THE WASHINGTON TIMES, L.L.C., publisher of

cW’.ntmc

Circulated daily, in the City of Washington, District of Columbia,and that the advertisement, of which the annexed is a true copy was

published in said newspaper .1 time(s) on the following dates:

2008 FEBRUARY 29

at the rate of $ 2.91 per line.

Total Cost $ 320.10 Dollars

(- i’( /7/

Subscribed and sworn to before me

FEBRUARY 29. 2008Notary Public..1tt?C

Faith H. Alibrifton

Notary Publjc, District of Columbia My Commij 0Expires 6-14-2010

• •I•.

My Commission expires
7.:.

•

•

it.. 1
GOVERNMENT OF THE DISTRICT OF COLUMBIA

Department of the Environment

Environmental Protection Administration

Air Quality Division

8

Public Hearing on Draft State Implementation Plan (SIP)

r Annual Fine Particle (PM2.5) Standard and 2002 Base Year Inventory

eadline, February 11, 2008, the Air Quality Division received one request for the opportunity to testify. Should

sons at the public hearing interested in making presentations who had missed the filing deadline, we will allow

for each person to testify. All presenters please sign in below:

AFFILIATION (if any) ADDRESS

J.

V

V