### GOVERNMENT OF THE DISTRICT OF 

### District Department ofthe Environ ent 

# ***

Office ofthe Director



### Shawn M. Garvin Regional Administrator, Region III U.S. Environmental Protection Agency Mail Code 3RAOO 1650 Arch Street Philadelphia, P A Subject: Section 11

### O(a)(2)(A)-(M) Requirements for the 008 Lead NAAQS in the Current District ofColumbia State Implementation Plan 

# Deary{**d7 l~** **~** Pursuant to the authority set forth in the District ofColumbia Ai Pollution Control Act of 1984 ("the Act"), Mayor's Order 98-44, dated AprillO, 1998, and M yor's Order 2006-61, dated June 14, 2006, the District ofColumbia (District) is hereby requestin approval ofa revision to its State Implementation Plan (SIP) submitted in accordance with t e requirements of40 C.F.R. Part 51. The District is requesting approval ofthis SIP revision to m et certain federal Clean Air Act (CAA) requirements under Sections 110(a)(2)(A) to (M). It

### is a compilation ofelements that describe how the District is implementing the "infrastructure" el ments ofthe 2008 lead (Pb) national ambient air quality standards (NAAQS). The District is also asking that the proposed Lead Infrastructure SIP submitted to the U.S. Environmental Protection Agency (EPA) on February 22,2012, as a SIP revision be withdrawn. A Notice ofPublic Hearing and Public Comment Period on this roposed SIP revision was posted in the D.C. Register 

### on June 7, 2013 (60 DCR 25: 00848 , Notice ID 4395378). A hard copy ofthe SIP submittal is enclosed with supporting do umentation:

DISTRICT DEPARTMENT OF THE ENVIRONMENT 

# • • • • Copy ofthe Pb Infrastructure SIP; Public hearing notice; Hearing officer's certification; One disk containing an electronic version ofthe SIP revi ion. The electronic version includes an exact duplicate ofthe paper copy ofthe SIP evision submittal.

g"enjo,wa'd 

# *

.. *

1200 First St. NE, 5th Floor, Washington, DC 200021 t 1: 202.535.2600 Iweb:ddoe.dc.gov

### Should you have any questions or require additional information, please contact me at (202) 535- 2615, or Ms. Cecily Beall, Associate Director for the Air Quality Division, at (202) 535-2626.

Director Enclosure

cc: Diana Esher, Director, Air Protection Division, EPA Region 3 Cecily Beall, Associate Director, Air Quality Division, DDOE

### GOVERNMENT OF THE DISTRICT OF District Department ofthe Environ ent 

# ***

Air Quality Division 

### MEMORANDUM TO:

FROM:

DATE: SUBJECT: Keith A. Anderson 

# \/A / I Director, District Department ofthe Environmen

### ~0) 17 

### 13. Abraham Hagos 

## Al/-1 7

# /r o/t3 Environmental Engineer, Permitting Branch, Air Quality Division, DDOE July 8, 2013 

### Hearing Officer's Certification for Public He rings on Two Separate SIP Revisions: (1) the District's Revised Conflict o Interest SIP and (2) the Lead Infrastructure SIP

This is to certify that two public hearings were held onJuly 8, 2 13, to give the public the opportunity to comment on proposed revisions to the District' s tate Implementation Plan (SIP). The first was held at approximately 5:00 p.m. to revise the confl ct ofinterest provisions included in the SIP to meet the requirements ofSection 128 oft e Clean Air Act. The second was held at approximately 5:30p.m. to revise the Lead (Pb) Inti structure SIP provisions. Notice ofboth public hearings was posted in the 

### D

.C. Register n June 7, 2013 (60 DCR 25: 008486, Notice ID 4395281 ; 60 DCR 25: 008485 , Notice ID 43 5378), as attached. Abraham Hagos ofthe District Department ofthe Environment, Air Quality Division, represented the District. No one attended either public hearing.

DISTRICT DEPARTMENT OF THE ENVIRONMENT

# ~ • .A. greenforward**H** 1200 First St. NE, 5th Floor, Washington, DC 200021 t 1 : 202.535.2600 

### Iweb:ddoe

.dc.gov

### DISTRICT DEP NOTICE OF PUBLIC H ON TMENT OFTHE EN RING AND PUBLIC OMMENT PERIOD R QUALITY ISSUES

Notice is hereby given that a publi hearing will be held on onday, July 8, 2013, at 5:30 p.m. in Room 555 at 1200 First treet NE, 5th Floor, in W shington, D.C. 20002. This hearing provides·interestedparties an opportunity to comme on the proposed revision to the District ofColumbia's (Distri t) State Implementation P n (SIP), found at 40 C.F.R. Part 52 Subpart J, regarding ce in federal Clean Air Act (CAA) requirements under Sections 110(a)(2)(A) to (M). he SIP revision was ini ially proposed in the D.C. Register 

### on February 8, 2013**(~0** 

### DCR 001391; Notice ID 4176061). Comments received from the United States**~nvironmental** 

### Protection gency (EPA) are addressed in this re-proposal. j 

### Once the District has completed its procedures, the propose revision to the SIP will be submitted to the EPA for approvaH This SIP revision is a**compila~ion** 

### of elements that d cribe how the District is implementing the "infrastructure'telements of the 2008 le d (Pb) national ambient air quality standards (NAAQS). 0 

### ce approved by EPA, · will provide a federally enforceable written confirmation f how the District will ontinue to comply with the §110(a)(2) requirements ofthe**C~** 

### for Pb.

I I 

### This SIP revision is being propo!ed simultaneously with a SIP revision to replace the District's conflict ofinterest provi ions to meet the requirem nts of§ 110(a)(2)(E)(ii) and § 128 ofthe CAA for all criteria p llutantNAAQS, notjustt e Pb NAAQS. Copies of the proposed SIP revtion are available for p blic review during normal business hours at the offices of e District Department o the Environment (DDOE), 1200 First Street NE, 5th loor, Washington, DC 20002, and on-line at http://ddoe.dc.gov/. · Interested parties wishing to testit' y at.

# t~is**h~aring** must su

# I?i~ in writing their names, addresses, telephone numbers and affihatton, tfany, to Mr. tlham Bolden at the DDOE address above or at william.boldfn@dc.gov by 4:00 p.m. n July 8, 2013. Interested parties may also submit written comments to Ms. Jessi Daniels, Monitoring and Assessment Branch, Air Quality pivision, DDOE, at the s me address or by email at jessica.daniels@dc.gov. Question about this SIP revision should be directed to Mr. Rama S. Tangirala by phone at 20 -535-2989 or email at ra a.tan ·rala de. ov, or Ms. Daniels at 202-741-0862 or ·essie .daniels de. ov. No com ents will be accepted after July 8, 2013.I 

### Notice ID 4395378: Environment,

## Distric~ Department ofthe- Noti e of

### Public Hearing a... 

### Page 1of1

• District of Columbia MAYOR DC GUIDE ESIDENTS BUSINESS VISITORS G VERNMENT FOR KIDS
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## D.C. Municipal Regulation; and D.C.**Registe~"** 

## :::::: Secretary of the District of Columbia I Office of DocumEnts and Administrative Issuances

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Notice ID: 4395378 i Environment, District Department of the -

## N~tice of Public Hearing and Pub ic Comment Period on Air Quality Issues - National Ambient Air Quality**Stand~rds** Register Category: Fjublic Hearing Agency Name: Environment, District Department of the

Notice Files:

# li;I

..{'r.V::-Ie-w-=Tex-1"1) Register Issue: E 7/2013 Vol 60/25

Publish Date: Ej/7/2013 How to Link to this Notice:**~ttp://www.dcregs.dc.gov/Gateway/NoticeHc** me.aspx?NoticeiD=4395378

Telephone Directory by Topic • Agencies • DC Council 

### •i Search • Elected Officials • Feedback • A essibility • Privacy & Security • Terms & Conditions I Office of Documents and Administrative Issuances 4 14th Street, NW, Suite 520S, Washington, DC 20001 Phone: (202) 727-5090 Fax: (202) 727-6042 Email: DCdocuments@dc.gov

# http://www.dcregs.dc.gov/Gateway/Noti~Home.aspx?Notice!D=4l95378 7/10/2013JULY 8, 2013

Please sign below:
NAME 

### 1. 2. 3. 

### 4. 5. 

### GOVERNMENT OF THE DISTRICT OF COLUMBIA 

## Department ofthe Environment Environmental Protection Administration Air Quality Division

PUBLIC HEARING ON THE LEAD INFRASTRUCTURE SIP AS A REVISION TO THE DISTRICT's STATE IMPLEMENTATION PLAN

AFFILIATION (ifany) ADDRESS

### 2008 Pb NAAQS (73 Fed. Reg. 66964) 110(a)(2)(A) through (M) 

### Requirements in the CurrentDistrict ofColumbia State Implementation Plan Revised May 2013 A state implementation plan (SIP) is a plan for each state that identifies how that state will attain and/or maintain the primary and secondary national ambient air quality standards (NAAQS). The SIP is a complex, living document containing regulations, sourcespecific requirements, non-regulatory items such as plans and inventories, and in some cases additional requirements promulgated by the U.S. Environmental Protection Agency (EPA). The initial SIPs for states were approved by EPA onMay 31, 1972. SIPs can be revised bythe state with EPA approval as necessary. The federally enforceable SIP for the District ofColumbia is compiled in 40 C.F.R. Part 52, Subpart

### J. Many ofthe miscellaneous requirements ofSection 11O(a)(2)(A) to (M) ofthe Clean AirAct (CAA) relevant to the 2008 Pb NAAQS are already contained intneDistrict ofColumbia's current SIP or SIP revisions which have been submitted to EPA. The following table summarizes where these fulfilled requirements ofSection 110(a)(2)(A) to (M) are addressed in the District ofColumbia's current SIP or SIP revisions, and may include elements which have not been addressed in previous SIP revisions.


### Section llO(a) Element §110(a)(2)(A)- Emission limits and other control measures 

### SummaryofElement "Each such plan shall [

...] include enforceable emission limitations and other control measures, means, or techniques (including economic incentives such as fees, marketable permits. and auctions ofemissions ri!ilits). as well as schedules and timetables for compliance as may be necessary or appropriate to meet the applicable requirements ofthis chapter."

1 

### Provisions in the Current District ofColumbia SIP Enforceable emissions limits, control measures, fees, and compliance methods related to Pb are found in the provisions of Title 20 ofthe District ofColumbia Municipal Regulations (20 DCMR) Chapters 2 (General_and_Nonattainment Area Permits). 3 (Operating Permits and Acid Rain Programs), and 6 (Particulates), portions ofwhich are in the District of Columbia's approved SIP and listed in 40C.F.R. § 

### 52.470(c). Control measures that are part ofthe Title V program are not a part ofthe District's SIP. EPA approved the District's Title V program on August 7, 1996 (60 Fed. Reg. 40101) and amendments to the program on April16, 2003 (68 Fed. Reg. 18548).Section llO(a) Element Summary ofElement Provisions in the Current District ofColumbia SIP §11O(a)(2)(B)- Ambient "Each such plan shall [

...] provide for establishment and The District ofColumbia decommissioned its Federal air quality monitoring/ data operation ofappropriate devices, methods, systems, and Reference Method (FRM) or federal equivalent method (FEM) system procedures necessary to Pb air quality monitoring network in December 2001 because ambient levels were consistently very low compared to the (i) monitor, compile, and analyze data on ambient air 1978 PbNAAQS. Air quality monitoring for Pb to determine quality, and compliance with the new 2008 NAAQS commenced by January 1, 2012, using FRM or FEM monitors, in accordance (ii) upon request, make such data available to the with EPA's December 14,2010, revisions to the Pb ambient air Administrator." monitoring network requirements. The District Department ofthe Environment (DDOE) operates and maintains air quality monitoring stations and equipment in the District ofColumbia and sends collected air samples to an EPA-approved lab for analysis. DDOE performs quality assurance checks, and submits the data to EPA's Air Quality System (AQS), in accordance with datareporting and ambient air data certification requirements. DDOE submits anAnnual Network Plan to EPA Region III that describes how the District ofColumbia has complied with monitoring requirements. It serves as prior notification ofany proposed changes to the monitoring sites or measurement methods. The Annual Network Plan provides descriptions of any proposed changes to the District ofColumbia's ambient air network, the reason for each change, and any other information relevant to the change. §110(a)(2)(C)- Programs "Eachplan shall [

...] include a program to provide for the Elements ofthe District's enforcement program that are in the for enforcement, PSD, and enforcement ofthe measures described in subparagraph SIP, including monitoring, recordkeeping, and reporting NSR (A), and regulation ofthe modification and construction of requirements, are found in parts of20 DCMR Chapters 1 and 5 any stationary source within the areas covered by the plan (e.g., Section 500 includes requirements for records and

I as necessary to assure that national ambient air quality reports, and§ 501 includes requirements for monitoring standards are achieved, including a permit program as devices). required in parts C and D ofthis subchapter." The District ofColumbia relies on a Federal Implementation


### 2Section llO(a) Element



### §11O(a)(2)(D)(i)- Interstate transport provisions Summary ofElement

+------------- "Each such plan shall [

...] contain adequate provisions (i) prohibiting, consistent with the provisions ofthis subchapter, any source or othertype ofemissions activity within the state from emitting any air pollutant in amounts which will (I) contribute significantly to nonattainment in, or interfere with maintenance by, any other State with respect

l.V CUI)' .3U""11 IIQ.LlUUQ.J _llllllla.l)' Vl i3t;i\.IVJIUQJ.)'**QJ.llUl~lU.** Q.ll quality standard, or (II) interfere with measures required to be included in the applicable implementation plan for any other State under part C ofthis subchapterto prevent significant deterioration ofair quality orto protect visibility."



### 3 Provisions in the Current District ofColumbia SIP Plan (FIP) containingthe federal Prevention ofSignificant Deterioration (PSD) program requirements of40 C.F.R. 

### § 52.21, as approved in the District's SIP at 40 C.F.R. 

### § 52.499 for criteria pollutants in attainment areas such as Pb. Together, the PSD FIP and the District's SIP-approved minor New Source Review (NSR) program at 20 DCMR Chapter 2 provide for permitting ofmajor (PSD) and new and modified minor (NSR) stationary sources ofPb. To the extent that 

### it refers topermitprograms known as "nonattainment new source review" underpartD, section JJO(a)(2(C) is outside the scope of this infrastructure SIP.

-----**-------~----** ----------------
-- (i)(I) Accordingto EPA's guidance on infrastructure SIP elements for the 2008 Pb NAAQS (October 14, 2011), "EPA's experience with initial Pb designations suggests that sources that emit less than 0.5 tons per year (tpy) orthat are located more thantwo miles from a state border generally appear unlikely to contribute significantly to nonattainment in another state." There are no Pb sources located within the District or in close proximity to its borders (e.g., within 2 miles) that have an emissions threshold of0.5 tons peryear or greater (see
1**.L1l~-~=:** r:t..'-I.U.""J.J.J.U.""J.U IJ, ;:)V UV ..LIJ;:)Ul""l. ;:)UUl\.1\;1 VVlll**'-'VllUlUUL~** significantly to nonattainment in, or interfere with maintenance by, any other state with respect to the Pb NAAQS. (i)(II) As mentioned inthe response to Part C, new major sources and major modifications in the District ofColumbia are subject to federal PSD requirements of40 C.F.R. 

### § 52.21, as approved inthe District's SIP at 40 C.F.R. 

### § 52.499 for criteria pollutants such as Pb. This permitting provision in the SIP does not interfere with measures required in any other state SIP to prevent significant deterioration ofair quality. Accordingto EPA's guidance on infrastructure SIP elements --------Section llO(a) Element Summary ofElement Provisions in the Current District ofColumbia SIP for the 2008 Pb NAAQS (October 14, 2011) with respect to the visibility requirement, "significant impacts from lead emissions from stationary sources are expected to be limited to short distances from the source... Furthermore, when EPA evaluated the extentthat lead could impact visibility, lead-related visibility impacts were found to be insignificant (e.g., less than 0.10%). See Analysis by Mark Schmidt, OAQPS, "Ambient Pb's Contribution to Class 1AreaVisibility Impairment," June 17, 20 11." The District ofColumbia does not contain a Class I area or any lead sources located over 50 miles from the closest Class I area (see Attachment 1). Thus, no interference with measures required ofany other state to protect visibility is anticipated. The District's Regional Haze SIP to address visibility impairment in Class I areas was approved by EPA on February 2, 2012 (77 Fed. Reg. 5191). §11O(a)(2)(D)(ii)- "Each such plan shall [

...] contain adequate provisions As approved in the District's SIP in 40 C.P.R.§ 52.499, the Interstate and International District relies onthe federal PSD program requirements of40 transport provisions (ii) insuring compliance with the applicable C.P.R.§ 52.21 to meet the requirements ofCAA § 126(a). requirements ofsections 115 and 126 (relating to interstate and international pollution abatement)." The District ofColumbia is not aware ofbeingthe subject of any petitions or pending actions related to interstate or international transport ofemissions from its sources, so has no continuing obligations under CleanAirAct § 115 (international transport) or§§ 126(b) or (c) (interstate transport) that involve Pb emissions at this time. §110(a)(2)(E)

- Adequate "Each such plan shall [

...] provide (i) DDOE believes that the District ofColumbia will personnel, funding, and continue to have adequate funding and personnel to carry out authority (i) necessary assurances that the state (or, except where the SIP with respect to Pb requirements. The primary sources the Administrator deems inappropriate, the general purpose offunding for the implementation ofthe Pb requirement are the local government or governments, or a regional agency Clean Air Act Section 105 federal grant funds and the District designated by the state or general purpose local ofColumbia's local match, and fees collected under the Title V
4Section UO(a) Element Summary ofElement governments for such purpose) will have adequate personnel, funding, and authority under state (and, as appropriate, local) law to carry out such implementation plan (and is not prohibited by any provision offederal or state law from carrying out such implementation plan or portion thereof); (ii) requirements that the state comply with the requirements respecting state boards under section 128, and program. Provisions in the Current District ofColumbia 

### SIP

DDOE does not anticipate the need for additional resources to carry out the plan for the Pb standard beyond those which have been utilized to date to meet other current programmatic demands. The District ofColumbia assures EPA that it has adequate statutory authority under the District ofColumbiaAir Pollution Control Act of 1984 (D.C. Official Code§§ 8-101 etseq. (2008 (iii) necessary assurances that, where the state has relied Repl.)) and the District Department ofthe Environment on a local orregional government, agency, or Establishment Act of2005 (D.C. Official Code§§ 8-151.01 et**~---** -+insttmnentality fot the implementation ofany plmt u-
u -- • • • • - 

### -+- provision, the state has responsibility for ensuring adequate to the 2008 Pb standards and to revise the SIP as necessary. implementation ofsuch plan provision." DDOE is not prohibited by any District ofColumbia law from carrying out any part ofthe implementation plan.



### 5 Organizations that typically participate in developing the District ofColumbia's SIPs and that carry out some SIP planningrequirements are represented by the Metropolitan Washington Air Quality Committee (MWAQC), an organization that has been certified by the Governors of**~** J\Lf.,,..,).,.,d .,.,d ''iraini., .,.,d th

.. 1\Lf.,.,nr n£th

.. n;.,tri,.t n£ •J**·~**..**~ -·~**  ...b

....**~-·~** ... _ ...**~J** Columbia under section 174 ofthe CAA (see Attachment 2) and includes representatives oflocal governments and agencies; and the Interstate Air Quality Council. In accordance with 40 C.F.R. § 51.240, each SIP identifies the responsibilities ofparticipating organizations and refers to related agreements among the organizations. (ii) The District ofColumbia does not have a board which approves permits or enforcement orders. The District's conflict ofinterest provisions at 40 C.F.R. 

### § 52.470(e) (also called the "CAA Section 128 SIP") require a high level ofethical conduct for all employees and public officials ofthe District --Section llO(a) Element Summary ofElement Provisions in the Current District ofColumbia SIP government, in accordance with the requirements ofthe Clean AirAct§ 128. Updates to the District's CAA 128 provisions are currently proposed to EPA as a SIP revision. (iii) The District ofColumbia does not rely on local or regional entities for carrying out any SIP obligations, so it maintains responsibility for ensuring adequate implementation ofplan provisions. §110(a)(2)(F)

- Stationary "Each such plan shall[

...] require, as may be prescribed by (i)-(ii) The requirements for source monitoring, source monitoring and the Administrator recordkeeping, and reporting are in 20 DCMR Chapter 5 reporting (Source Monitoring and Testing), Sections 500 (Records and (i) the installation, maintenance, and replacement of Reports), 501 (Monitoring Devices), and 502 (Sampling, Tests equipment, and the implementation ofother necessary steps and Measurements), portions ofwhich are in the District of by owners or operators ofstationary sources to monitor Columbia's approved SIP and listed in 40 C.F.R. § 52.470(c). emissions from such sources, The requirements that provide for monitoring the status of (ii) periodic reports on the nature and amounts of sources' compliance with the NAAQS are in 20 DCMR emissions and emissions-related data from such sources, Chapter 2 (General and Non-Attainment AreaPermits) and Chapter 3 (Operating Permits and Acid Rain Programs), (iii) correlation ofsuch reports by the state agency with portions ofwhich are in the District ofColumbia's approved any emission limitations or standards established pursuant SIP and listed in 40 C.F.R. 

### § 52.470(c). to this Act, which reports shall be available at reasonable times for public inspection." DDOE also submits annual point source emissions inventory datato EPA through the Emissions Inventory System, in accordance with 40 C.F.R. §Part 51 Subpart A, the Air Emissions Reporting Requirements. (iii) Air quality inspectors analyze emissions data and correlate such data with any applicable emission limitations or standards. All emissions reports are available for public inspection through the District's normal administrative procedures, such as under the District ofColumbia's Freedom ofInformation Act (FOIA) (D.C. Official Code 

### § 2-531 etseq.. (2008 Repl.)).


### 6Section 110(a) Element §110(a)(2)(G)- Emergency episodes**--a-~-**

§II0( a)(2)(H)

- Future SIP revisions Summary ofElement "Each such plan shall [

...] provide for authority comparable to that in section 303 and adequate contingency plans to implement such authority."

"Each such plan shall [

...] provide for revision ofsuch plan (i) from time to time as may be necessary to take account ofrevisions ofsuch national primary or secondary ambient air quality standard orthe availability ofimproved or more expeditious methods ofattaining such standard, and (ii) except as provided in paragraph (3)(C), whenever the Administrator finds onthe basis ofinformation


### 7 Provisions in the Current District ofColumbia SIP Section 6 ofthe District ofColumbia Air Pollution Control Act of 1984 (D.C. Official Code§§ 8-101 etseq. (2008 Repl.)) and the District Department ofthe Environment Establishment Act of2005 (D.C. Official Code§§ 8-151.01 etseq. (2008 Repl.)), provide the statutory authority for 20 DCMRChapter 4 (Ambient Monitoring, Emergency Procedures, Chemical Accident Prevention and Conformity), Section 401 (Emergency Procedures). Section 401 provides the Mayor with authority to restrain any source from causing or contributingto Pb emissions which present an imminent and substantial endangerment to public health, welfare orthe environment, or to take other action as may be necessary. Section 401 is inthe District ofColumbia's approved SIP and listed at 40 C.F.R.-g52.470(c). The District ofColumbia has a general Emergency Episode Plan from I976, which includes procedures for reducing emissions from the source at issue (ifnecessary, by curtailing operations) and informing the public, as needed. It would be burdensome to adopt a more specific contingency plan at this time because historically, ambient monitoring data has shown that Pb levels are very low, and there are no Pb sources of +1....., n'll!_,.,.... ....,,.1!....,,.,.**~··--~A** ++nnL......,,.,...,+_1_

_ _L .l.l.l \..1.1""**~UJ..lVUJ.I.U.J.J.J.5** UJ.\o.IU. \.U\ol'\.1**~l.l.U'-'J.ll.l.l\ooiJ.J.\,** .L .l.V.l details.) {i)-(ii) The District ofColumbiahas adequate authority underthe District ofColumbiaAir Pollution Control Act of I984 (D.C. Official Code§§ 8-IOI etseq. (2008 Repl.)) and the District Department ofthe Environment EstablishmentAct of2005 (D.C. Official Code§§ 8-I5l.OI etseq. (2008 Repl.)), to revise the SIP. The District ofColumbia will review and revise its SIP from time to time as may be necessary to take account ofrevisions to the primary or secondary NAAQS orthe availability of -Section UO(a) Element

§11O(a)(2)(1)- Nonattainment areaplan or plan revision Under Part D
§11O(a)(2)(J)- Consultation with government officials, public notification, PSD and visibility protection Summary ofElement available to the Administrator that the plan is substantially inadequate to attainthe national ambient air quality standard which it implements, or to otherwise comply with any additional requirements established under this chapter (CAA)." "Each such plan shall [

...] in the case ofa plan or plan revision for an area designated as a nonattainment area, meet the applicable requirements ofpart D orthis subchapter (relating to nonattainment areas)." "Each such plan shall [

...] meet the applicable requirements ofsection 121 ofthistitle (relating to consultation), section 127 ofthis title (relating to public notification), and part C ofthis subchapter (relating to prevention ofsignificant deterioration ofair quality and visibility protection)."



### 8 Provisions in the Current District ofColumbia SIP improved or more expeditious methods ofattaining a standard, and wheneverthe Administrator finds onthe basis of information available to the Administratorthatthe plan is substantially inadequate to attain the NAAQS.

Nonattainment areaplans required underpartDare required on a different schedule from the section 110 infrastructure elements andwill be reviewedandacted upon through a separateprocess. The District ofColumbia provides a process ofconsultation with general purpose local governments, designated organizations ofelected officials oflocal governments, and federal land managers under sections 5(a)(3) and 5(b)(5) ofthe District ofColumbiaAir Pollution Control Act of 1984 (D.C. Official Code§§ 8-101 etseq. (2008 Repl.)) andthe District Department ofthe Environment Establishment Act of2005 (D.C. Official Code§§ 8-151.01 etseq. (2008 Repl.))). Through the Metropolitan Washington Air Quality Committee (MW AQC), an organization that has been certified by the Governors ofMaryland and Virginia andthe Mayor ofthe District ofColumbia under section 174 ofthe CAA and includes representatives oflocal governments and agencies, and its partners (see Attachment 2), the public is regularly notified ofand educated about NAAQS exceedances. As discussed under provisions for§§ 110(a)(2)(C) and 110(a)(2)(D)(i), the District ofColumbia relies on the federal PSD program requirements of40 C.F.R. § 52.21, as adopted in the District's SIP at 40 C.F.R. § 52.499

.. Visibility obligations under this infrastructure element are not llQI>licable.Section 110(a) Element §110(a)(2)(K)

- Air quality modeling/data Summary ofElement "Each such plan shall [

...] provide for (i) the performance ofsuch air quality modeling as the Administrator may prescribe for the purpose ofpredicting the effect on ambient air quality ofany emissions ofany air pollutant for which the Administrator has established a national ambient air quality standard, and (ii) the submission, upon request, ofdata related to such air quality modeling to the Administrator." Provisions in the Current District ofColumbia SIP (i) Mayoral authority to perform air quality modeling is established under sections S(a)((l) and 5(b)(3) ofthe District of ColumbiaAir Pollution Control Act of 1984 (D.C. Official Code§ 8-101.05(a)(1) and (b)(3) (2008 Repl.)). Section 105 of the District Department ofthe Environment Establishment Act of2005 (D.C. Official Code§ 8-151.05 (2008 Repl.)) and Mayor's Order 2006-61 (Delegation and Transfer of Authority Pursuant to D.C. Law 16-51, the DistrictDepartment of the EnvironmentEstablishmentAct of2005 (53 D.C. Reg. 5694, July 14, 2006)) then delegates authority from the Mayorto DDOE. In addition, the federal PSD program regulations, as adopted in the District's SIP at 40 C.F.R. § 52.499, require**~---~~** ------- -+---
--**~** -- -----
--- --------**~--~---** 

### ------fpermit applicants 

### to conduct air quality impacts modeling 

# I analyses for purposes ofregulating the construction and modification ofstationary sources.

§110(a)(2)(L)

- Permitting fees "Each such plan shall [

...] require the owner or operator of each major stationary source to pay to the permitting authority, as a condition ofany permit required under this chapter, a fee sufficient to cover:



### 9 Currently, no lead source in the District ofColumbiarequires the use ofsource-oriented dispersion modeling. In the future, should modeling for lead become necessary, the District of Columbia can and will develop the technical capability to conduct modeling in order to assess the effect on ambient air quality ofrelevant pollutant emissions. (ii) Upon request, the District ofColumbia can and will submit relevant current andfuture data relating to air quality modeling to the Administrator as part ofthe permitting and NAAQS implementation processes, as outlined in 20 DCMR Chapter 3 (Operating Permits and Acid Rain Programs) Section 303 (Permit Issuance, Renewal, Reopenings, and Revisions). (i)-(ii) Permit fees are collected according the Title V permit program under 20 DCMR Chapter 3 (Operating Permits and Acid Rain Programs), Section 305 (Permit Fees).Section llO(a) Element

§110(a)(2)(M)- Consultation/ participation by affected local entities Summary ofElement (i) the reasonable costs ofreviewing and actingupon any application for such a permit, and (ii) ifthe owner or operator receives a permit for such source, the reasonable costs ofimplementing and enforcing the terms and conditions ofany such permit (not including any court costs or other costs associated with any enforcement action), until such fee requirement is superseded with respect to such sources by the Administrator's approval ofa fee program under subchapter (title) V ofthis chapter." "Each such plan shall [

...] provide for consultation and participation by local political subdivisions affected by the plan."



### 10 Provisions in the Current District ofColumbia 

### SIP Permitting fees related to the Title V program are not a part of the District's SIP. However, EPA approved the District's Title V program on August 7, 1996 (60 Fed. Reg. 40101) and amendments to the program onApril16, 2003 (68 Fed. Reg. 18548).

Organizations that typically participate in developing the District ofColumbia's SIPs and that carry out some SIP planning requirements are represented by the Metropolitan Washington Air Quality Committee (MWAQC), an organization that has been certified by the Governors of Maryland and Virginia andthe Mayor ofthe District of Columbia under section 174 ofthe CAA (see Attachment 2) and includes representatives oflocal governments and agencies; and the Interstate Air Quality Council. In accordance with 40 C.F.R. § 51.240, each SIP identifies the responsibilities ofparticipating organizations and refers to related agreements amongthe organizations. All SIP revisions have gone through public notice and hearing, as specified by section 6 ofthe D.C. Administrative Procedure Act (D.C. Official Code, §2-505), and the District Department ofthe Environment Establishment Act of2005 (D.C. Official Code§ 8-151.07(3) (2008 Repl.)), and in accordance with EPA requirements at 40 C.F.R. § 51.102, which allow for comment by the public, including local political subdivisions affected by the SIP.ATTACHMENT 

### 1 

### 2008 Pb

## ~AAQS (73 Fed. Reg. 

### 66 64) District otColumbia lnfrastructur SIP I 

### May2013

Include an explanation in support of the nclusion that no source illconlribute significantly to nonattainmentor interfere with maintena ce of the Pb NAAQS in a ther state.

Demonstrate that the Districtdoes notne d a specific contingencyp an for lead. Ambient lead (Ph) monitoring in the Dist ict ofColumbia (District) egan in the 1960s. The District's Federal Reference Method (FRM) Ph mo itoring network was disco tinued in December 2001 in consultation with EPA when the monitor d ambient Ph concentratio s were consistently well below the 1978 Ph NAAQS of 1.5 J.lg/m3

. 

### For exa pie, the design value in th District for the 1998 to 1999 period (based on certified data that was s bmitted to EPA's Aerome ric Information Retrieval System, now known as the Air Quality System) w s 0.03 J.lg/m3• 

### The design concentration was about two percent ofthe 1978 NAAQS. Ambient P trends in the Districtpar leled national Ph trends at the time.

I 

### During 2001 and 2002, the District establ shed a Chemical Speciati Network (CSN) monitor for measuring chemical species offine partie late matter (PM2.5) 

### polluti n, and National Air Toxics Trends Station (NATTS) monitors for measuring air toxics, including ambi nt Ph. These monitoring networks are based on air sampling ofparticulate atterpollution of2.5 micr ns (PM2.5) 

### and 10 microns (PM10) in diameter. Even though the CSN and TTS monitors are not ap roved FRM Ph monitors, the recent data from the District's CSN and NATTS indicate ambient Ph conce**tratio~s** 

### in the range of0.01 J.lg/m3

, 

### which is still farbelow the 2008 standard f 0.15 J.lg/m3• 

### The District plans to commence

### populati~n-based ambient Ph monit ring with EPA-approved FRM samplers by January 1, 2012, in order to rpeet the monitoring requir ments ofthe 2008 Ph NAAQS.

r 

### According to EPA's October 14, 2011,**p~'** 

### Infrastructure SIP Guida e, "EPA's experience with initial Ph designations suggests that sources tha emit less than 0.5 ton per ear (tpy) or that are located more than two miles from a state border genera ly appear unlikely to cont 'bute significantly to nonattainment in another state." Levels from heliports afd stationary point sources in the District are orders of magnitude lower than the threshold, as in icated by EPA's Toxics lease Inventory (TRI, 2005) and a recent EPA inventory ofairport emission (2008). For example:

I



### Currently, the District is not aware ofany plans to establish a source that emits substantial amounts of Ph within its borders. Thus, it is reasona le to conclude that no sou e will contribute significantly to nonattainment or interfere with mainten ce ofthe NAAQS in anot er state. Also, there are no Ph sources ofconcern in the surrounding are .

### Section 110(a)(2)(D)(i): Interstate Transport Provisions, Part II Include an explanation in support of the conclusion that no Pb source will impair visibility at Class I areas. 

### The following map from the District' s Regional Haze SIP indicates that the Benning Road Generating Station, located in the northeast quadrant ofthe District along the Anacostia River, is roughly 100 km (62 miles) from Shenandoah National Park, the closest Class I area to the District.

Legend 

# * PPR Benrung Road Generating Stat ion

• NPS Class I Areas 

## •**6: ~s** **'tr ~!** **S**

liS R ht,

... 

### ..,. \\ 

# * .1J t l• 

# ..,

N 

# A Source: Draft B ARTanal ysi spr e pared b y ENS RI

AECOMf or PE PCO E ner gy S ystems (October 2008) 

### According to the Pb Infrastructure SIP Guidance, "significant impacts from Pb emissions from stationary sources are expected to be limited to short distances from the source. " More than 50 miles is considered to be more than a "short distance" from a Class I area for purposes ofthis SIP. In addition, EPA analysis oftotal versus Ph-associated light extinction at 164 IMPROVE and 117 CSN monitoring sites has determined that Pb-related visibility effects (in Class I and other areas) are insignificant in comparison to those associated with sulfate, nitrate, and carbon PM (see Mark Schmidt memo, OAQPS, "Ambient Pb's Contribution to Class I Area Visibility Impairment," 11/7/2011). Thus, visibility impairment related to ambient Pb is not a notable concern.I 

### THE DJSTJUCT OF COLUMBIA

WAS,INGTON. D.C. 20004 .MAIIION

...,.,.,.,.DIXON


# ........ I

• • I 

### Bonorable James B. Ratbanaon I 

### Cbairman, Boar.S of Directors I· 

### Metropolitan Washington 

## Councill 

## 777 North Capitol 

## Street, R.B. Suite 300 ! · 

### Washington 

## D.C. 20002 · Dear 

### Mr. Na.tbanson:**~-7,** 

### 191



### of 

## Governments

'•



## This letter 

## certifies ray appr litiui 

### Washington Air Quality Committee 

## serve a : the**ent~ty** 

## respo sib.le for**car~ing** 

## out the planning requirements of the Clean Air ct Aaendaenta of 1990 for 

## the washington D.C./**arylan~/Virginia** 

### rea. 

## I 

## look forward to your 

## continued ass stance.in camplyi g vith this significant environmental qua 

### ity program. · . . ·

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