GOVERNMENT OF THE DISTRICT OF 

District Department of the Environ ent 

*** 

Office of the 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 of Columbia State Implementation Plan 

Dear y{ d7l~~ 

Pursuant to the authority set forth in the District of Columbia 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 of Columbia (District) is hereby requestin approval of a revision to its 

State Implementation Plan (SIP) submitted in accordance with t e requirements of 40 C.F.R. Part 

51. The District is requesting approval of this SIP revision to m et certain federal Clean Air Act 

(CAA) requirements under Sections 110(a)(2)(A) to (M). It is a compilation of elements that 

describe how the District is implementing the "infrastructure" el ments of the 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Environmental Protection Agency (EPA) on February 22,2012, as a SIP revision be withdrawn.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 of Public 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 of the SIP submittal is enclosed with supporting do umentation: 

DISTRICT 

DEPARTMENT 

OF THE 

ENVIRONMENT 

• 

• 

• 

• 

Copy of the Pb Infrastructure SIP; 

Public hearing notice; 

Hearing officer's certification; 

One disk containing an electronic version of the SIP revi ion. The electronic version 

includes an exact duplicate of the paper copy of the SIP evision submittal. 

g"enjo,wa'd * .. * 

1200 First St. NE, 5th Floor, Washington, DC 200021 t 1: 202.535.2600 I web: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 of the Environ ent 

*** 

Air Quality Division 

MEMORANDUM 

TO: 

FROM: 

DATE: 

SUBJECT: 

Keith A. Anderson \/A / I 

Director, District Department of the 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 on July 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 of interest provisions 

included in the SIP to meet the requirements of Section 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 of both 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 of the District Department of the Environment, Air Quality Division, 

represented the District. No one attended either public hearing. 

DISTRICT 

DEPARTMENT 

OF THE 

ENVIRONMENT 

greenforward ~ • .A. H 

1200 First St. NE, 5th Floor, Washington, DC 200021 t 1: 202.535.2600 I web:ddoe.dc.gov 
DISTRICT DEP 

NOTICE OF PUBLIC H 

ON 

TMENT OF THE 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·interested parties an opportunity to comme on the proposed revision to 

the District of Columbia'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 of interest provi ions to meet the requirem nts of§ 110(a)(2)(E)(ii) and 

§ 128 of the CAA for all criteria p llutant NAAQS, not just t 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, tf any, 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 of the- Noti e of Public Hearing a ... Page 1 of 1 

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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 7/10/2013 
JULY 8, 2013 

Please sign below: 

NAME 

1. 

2. 

3. 

4. 

5. 

GOVERNMENT OF THE DISTRICT OF COLUMBIA 

Department of the 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 (if any) ADDRESS 
2008 Pb NAAQS (73 Fed. Reg. 66964) 

110(a)(2)(A) through (M) Requirements in the Current District of Columbia 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 on May 31, 1972. SIPs can be 

revised by the state with EPA approval as necessary. The federally enforceable SIP for the District of Columbia is compiled in 40 

C.F.R. Part 52, Subpart J. 

Many of the miscellaneous requirements of Section 11 O(a)(2)(A) to (M) of the Clean Air Act (CAA) relevant to the 2008 Pb NAAQS 

are already contained in tneDistrict of Columbia's current SIP or SIP revisions which have been submitted to EPA. The following 

table summarizes where these fulfilled requirements of Section 110(a)(2)(A) to (M) are addressed in the District of Columbia'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 

Summary of Element 

"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 of emissions ri!ilits). as 

well as schedules and timetables for compliance as may be 

necessary or appropriate to meet the applicable 

requirements of this chapter." 

1 

Provisions in the Current 

District of Columbia SIP 

Enforceable emissions limits, control measures, fees, and 

compliance methods related to Pb are found in the provisions of 

Title 20 ofthe District of Columbia Municipal Regulations (20 

DCMR) Chapters 2 (General _and_Nonattainment Area Permits). 

3 (Operating Permits and Acid Rain Programs), and 6 

(Particulates), portions of which are in the District of 

Columbia's approved SIP and listed in 40C.F.R. § 52.470(c). 

Control measures that are part of the Title V program are not a 

part of the 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 of Element Provisions in the Current 

District of Columbia SIP 

§ 11 O(a)(2)(B)- Ambient "Each such plan shall [ ... ] provide for establishment and The District of Columbia decommissioned its Federal 

air quality monitoring/ data operation of appropriate 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 Pb NAAQS. 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 of the Environment (DDOE) operates 

and maintains air quality monitoring stations and equipment in 

the District of Columbia 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 data reporting and ambient 

air data certification requirements. 

DDOE submits an Annual Network Plan to EPA Region III that 

describes how the District of Columbia has complied with 

monitoring requirements. It serves as prior notification of any 

proposed changes to the monitoring sites or measurement 

methods. The Annual Network Plan provides descriptions of 

any proposed changes to the District of Columbia's ambient air 

network, the reason for each change, and any other information 

relevant to the change. 

§ 110(a)(2)(C)- Programs "Each plan shall [ ... ] include a program to provide for the Elements of the District's enforcement program that are in the 

for enforcement, PSD, and enforcement of the measures described in subparagraph SIP, including monitoring, recordkeeping, and reporting 

NSR (A), and regulation of the modification and construction of requirements, are found in parts of 20 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 of this subchapter." 

The District of Columbia relies on a Federal Implementation 

2 
Section llO(a) Element 

§ 11 O(a)(2)(D)(i)-

Interstate transport 

provisions 

Summary of Element 

+-------------

"Each such plan shall [ ... ] contain adequate provisions 

(i) prohibiting, consistent with the provisions of this 

subchapter, any source or other type of emissions 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 of this subchapter to prevent significant 

deterioration of air quality or to protect visibility." 

3 

Provisions in the Current 

District of Columbia SIP 

Plan (FIP) containing the federal Prevention of Significant 

Deterioration (PSD) program requirements of 40 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 of major (PSD) and new and modified minor 

(NSR) stationary sources of Pb. 

To the extent that it refers to permit programs known as 

"nonattainment new source review" under part D, section 

JJO(a)(2(C) is outside the scope of this infrastructure SIP. ----- -------~---- ------------------

(i)(I) According to 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) or that are located 

more than two 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 of 0.5 tons per year 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 in the response to Part C, new major 

sources and major modifications in the District of Columbia are 

subject to federal PSD requirements of 40 C.F.R. § 52.21, as 

approved in the 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 of air quality. 

According to EPA's guidance on infrastructure SIP elements 

--------
Section llO(a) Element Summary of Element Provisions in the Current 

District of Columbia 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 extent that 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 1 Area Visibility Impairment," June 

17, 20 11." The District of Columbia 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 of any 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). 

§ 11 O(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 on the federal PSD program requirements of 40 

transport provisions (ii) insuring compliance with the applicable C.P.R.§ 52.21 to meet the requirements ofCAA § 126(a). 

requirements of sections 115 and 126 (relating to interstate 

and international pollution abatement)." The District of Columbia is not aware ofbeing the subject of 

any petitions or pending actions related to interstate or 

international transport of emissions from its sources, so has no 

continuing obligations under Clean Air Act § 115 (international 

transport) or§§ 126(b) or (c) (interstate transport) that involve 

Pb emissions at this time. 

§ 11 0( a)(2)(E) - Adequate "Each such plan shall [ ... ] provide (i) DDOE believes that the District of Columbia 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 of funding for the implementation of the 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 of Columbia's local match, and fees collected under the Title V 

4 
Section UO(a) Element Summary of Element 

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 of federal 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 of Columbia 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 of Columbia assures EPA that it has adequate 

statutory authority under the District of Columbia Air Pollution 

Control Act of 1984 (D.C. Official Code§§ 8-101 et seq. (2008 

(iii) necessary assurances that, where the state has relied Repl.)) and the District Department of the Environment 

on a local or regional government, agency, or Establishment Act of2005 (D.C. Official Code§§ 8-151.01 et 

~--- -+insttmnentality fot the implementation of any plmt u- u -- • • • • - -+-

provision, the state has responsibility for ensuring adequate to the 2008 Pb standards and to revise the SIP as necessary. 

implementation of such plan provision." DDOE is not prohibited by any District of Columbia law from 

carrying out any part of the implementation plan. 

5 

Organizations that typically participate in developing the 

District of Columbia'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 ~ 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 of local governments and 

agencies; and the Interstate Air Quality Council. In accordance 

with 40 C.F.R. § 51.240, each SIP identifies the responsibilities 

of participating organizations and refers to related agreements 

among the organizations. 

(ii) The District of Columbia does not have a board which 

approves permits or enforcement orders. The District's conflict 

of interest provisions at 40 C.F.R. § 52.470(e) (also called the 

"CAA Section 128 SIP") require a high level of ethical conduct 

for all employees and public officials of the District 

--
Section llO(a) Element Summary of Element Provisions in the Current 

District of Columbia SIP 

government, in accordance with the requirements of the Clean 

Air Act§ 128. Updates to the District's CAA 128 provisions 

are currently proposed to EPA as a SIP revision. 

(iii) The District of Columbia does not rely on local or 

regional entities for carrying out any SIP obligations, so it 

maintains responsibility for ensuring adequate implementation 

of plan provisions. 

§ 11 0( 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 of other necessary steps and Measurements), portions of which are in the District of 

by owners or operators of stationary 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 Area Permits) and 

Chapter 3 (Operating Permits and Acid Rain Programs), 

(iii) correlation of such reports by the state agency with portions of which are in the District of Columbia'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 

data to 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 of Columbia's Freedom 

of Information Act (FOIA) (D.C. Official Code § 2-531 et seq .. 

(2008 Repl.)). 

6 
Section 110(a) Element 

§110(a)(2)(G)- Emergency 

episodes 

--a-~-

§II 0( a)(2)(H) - Future SIP 

revisions 

Summary of Element 

"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 of such plan 

(i) from time to time as may be necessary to take 

account of revisions of such national primary or secondary 

ambient air quality standard or the availability of improved 

or more expeditious methods of attaining such standard, 

and 

(ii) except as provided in paragraph (3)(C), whenever 

the Administrator finds on the basis of information 

7 

Provisions in the Current 

District of Columbia SIP 

Section 6 of the District of Columbia Air Pollution Control Act 

of 1984 (D.C. Official Code§§ 8-101 et seq. (2008 Repl.)) and 

the District Department ofthe Environment Establishment Act 

of2005 (D.C. Official Code§§ 8-151.01 et seq. (2008 Repl.)), 

provide the statutory authority for 20 DCMR Chapter 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 contributing to Pb 

emissions which present an imminent and substantial 

endangerment to public health, welfare or the environment, or 

to take other action as may be necessary. Section 401 is in the 

District of Columbia's approved SIP and listed at 40 C.F.R.-g52.470(c). 

The District of Columbia has a general Emergency Episode 

Plan from I976, which includes procedures for reducing 

emissions from the source at issue (if necessary, 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 of Columbia has adequate authority 

under the District of Columbia Air Pollution Control Act of 

I984 (D.C. Official Code§§ 8-IOI et seq. (2008 Repl.)) and 

the District Department of the Environment Establishment Act 

of2005 (D.C. Official Code§§ 8-I5l.OI et seq. (2008 Repl.)), 

to revise the SIP. 

The District of Columbia will review and revise its SIP from 

time to time as may be necessary to take account of revisions to 

the primary or secondary NAAQS or the availability of 

-
Section UO(a) Element 

§ 11 O(a)(2)(1)-

Nonattainment area plan or 

plan revision Under Part D 

§ 11 O(a)(2)(J)-

Consultation with 

government officials, 

public notification, PSD 

and visibility protection 

Summary of Element 

available to the Administrator that the plan is substantially 

inadequate to attain the 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 of a plan or plan 

revision for an area designated as a nonattainment area, 

meet the applicable requirements of part D or this 

subchapter (relating to nonattainment areas)." 

"Each such plan shall [ ... ] meet the applicable requirements 

of section 121 ofthis title (relating to consultation), section 

127 of this title (relating to public notification), and part C 

of this subchapter (relating to prevention of significant 

deterioration of air quality and visibility protection)." 

8 

Provisions in the Current 

District of Columbia SIP 

improved or more expeditious methods of attaining a standard, 

and whenever the Administrator finds on the basis of 

information available to the Administrator that the plan is 

substantially inadequate to attain the NAAQS. 

Nonattainment area plans required under part Dare required 

on a different schedule from the section 110 infrastructure 

elements and will be reviewed and acted upon through a 

separate process. 

The District of Columbia provides a process of consultation 

with general purpose local governments, designated 

organizations of elected officials of local governments, and 

federal land managers under sections 5(a)(3) and 5(b)(5) of the 

District of Columbia Air Pollution Control Act of 1984 (D.C. 

Official Code§§ 8-101 et seq. (2008 Repl.)) and the District 

Department of the Environment Establishment Act of 2005 

(D.C. Official Code§§ 8-151.01 et seq. (2008 Repl.))). 

Through the Metropolitan Washington Air Quality Committee 

(MW AQC), an organization that has been certified by the 

Governors of Maryland and Virginia and the Mayor of the 

District of Columbia under section 17 4 of the CAA and 

includes representatives of local governments and agencies, and 

its partners (see Attachment 2), the public is regularly notified 

of and educated about NAAQS exceedances. 

As discussed under provisions for§§ 110(a)(2)(C) and 

110(a)(2)(D)(i), the District of Columbia relies on the federal 

PSD program requirements of 40 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 

§ 11 0( a)(2)(K) - Air quality 

modeling/data 

Summary of Element 

"Each such plan shall [ ... ] provide for 

(i) the performance of such air quality modeling as the 

Administrator may prescribe for the purpose of predicting 

the effect on ambient air quality of any emissions of any air 

pollutant for which the Administrator has established a 

national ambient air quality standard, and 

(ii) the submission, upon request, of data related to such 

air quality modeling to the Administrator." 

Provisions in the Current 

District of Columbia SIP 

(i) Mayoral authority to perform air quality modeling is 

established under sections S(a)((l) and 5(b)(3) ofthe District of 

Columbia Air 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 of the 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 District Department of the 

Environment Establishment Act of2005 (53 D.C. Reg. 5694, 

July 14, 2006)) then delegates authority from the Mayor to 

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 of regulating the construction and 

modification of stationary sources. 

§ 11 0( 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 of any permit required under this 

chapter, a fee sufficient to cover: 

9 

Currently, no lead source in the District of Columbia requires 

the use of source-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 of relevant pollutant emissions. 

(ii) Upon request, the District of Columbia can and will 

submit relevant current and future data relating to air quality 

modeling to the Administrator as part of the 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 of Element 

(i) the reasonable costs of reviewing and acting upon 

any application for such a permit, and 

(ii) if the owner or operator receives a permit for such 

source, the reasonable costs of implementing and enforcing 

the terms and conditions of any 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 of a 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 of Columbia 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 on April16, 2003 (68 Fed. Reg. 

18548). 

Organizations that typically participate in developing the 

District of Columbia'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 and the Mayor of the District of 

Columbia under section 174 of the CAA (see Attachment 2) 

and includes representatives of local governments and 

agencies; and the Interstate Air Quality Council. In accordance 

with 40 C.F .R. § 51.240, each SIP identifies the responsibilities 

of participating organizations and refers to related agreements 

among the organizations. 

All SIP revisions have gone through public notice and hearing, 

as specified by section 6 of the D.C. Administrative Procedure 

Act (D.C. Official Code, §2-505), and the District Department 

of the 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 ot Columbia lnfrastructur SIP 

I May2013 

Include an explanation in support of the nclusion that no source ill conlribute significantly to 

nonattainment or interfere with maintena ce of the Pb NAAQS in a ther state. 

Demonstrate that the District does not ne d a specific contingency p an for lead. 

Ambient lead (Ph) monitoring in the Dist ict of Columbia (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 of the 1978 NAAQS. Ambient P trends in the District par 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 of fine 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 of particulate atter pollution of 2.5 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 of 0.01 J.lg/m3

, 

which is still far below 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 of the 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 of airport emission (2008). For example: 

I 

Currently, the District is not aware of any 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 of the NAAQS in anot er state. Also, there are no Ph 

sources of concern in the surrounding are . 
Section 11 0(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 of the 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 Station 

• NPS Class I Areas 

• 6:~s 'tr~! S 

liS Rht, ... ..,. \\ 

* .1J t l• .. , 

N 

A 

Source: Draft BART analysis prepared by ENSRIAECOMfor PEPCO Energy Systems (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 of this SIP. 

In addition, EPA analysis of total 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. · . . · 

2-31