**SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST**

(in accordance with 40 CFR Part 51 - App. V)

SIP Submitted by: **Commonwealth of Pennsylvania**

Date Submitted: **September 25, 2006**

Subject: **Reasonably Available Control Technology (RACT) for
Philadelphia County**

Completeness Review **Base File Number: PA229**

**S/S**

Completed by: **Christopher Cripps, 3AP21**

Date Completed: ***March 26, 2007***

**Administrative Materials**

**ACCEPTABLE**

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  **EPA REQUIREMENT**                **STATE SUBMITTAL**              **(X)**
  ---------------------------------- -------------------------------- ---------
  1\. A formal letter of submittal   1\. . Letter from Kathleen A.    X
  from the Governor or his designee, McGinty, Secretary of the        
  requesting EPA approval of the     Pennsylvania Department of       
  plan or revision thereof.          Environmental protection dated   
                                     September 25, 2006.              

  2\. Evidence that the State has    2\. Not a regulatory change. The X
  adopted the plan in the State code submittal is a certification     
  or body of regulations; or issued  that the Pennsylvania RACT       
  the permit, order, consent         regulations meet RACT for the    
  agreement in final form. That      8-hour ozone NAAQS. The          
  evidence shall include the date of certification is effective       
  adoption or final issuance as well September 2006.                  
  as the effective date of the plan,                                  
  if different from the                                               
  adoption/issuance date.                                             

  3\. Evidence that the State has    3\. State has legal authority to X
  the necessary legal authority      adopt this RACT certification    
  under State law to adopt and       under Section 5 of the Air       
  implement the plan.                Pollution Control Act.           
                                     Philadelphia AMS has the         
                                     authority to adopt and develop   
                                     the certification under          
                                     Philadelphia Air management Code 
                                     §3-301 of the Philadelphia Code  
                                     and 25 Pennsylvania Code,        
                                     Subpart C, Article III.          

  4\. A copy of actual regulation,   4\. The submittal is a           X
  or document submitted for approval certification that the           
  and incorporation by reference     Pennsylvania RACT regulations    
  into the plan, including           meet RACT for the 8-hour ozone   
  indication of the changes made to  NAAQS. The certification is      
  the existing approved plan, where  effective September 2006.        
  applicable. The submittal shall be                                  
  a copy of the official State                                        
  regulation/document signed,                                         
  stamped, dated by the appropriate                                   
  State official indicating that it                                   
  is fully enforceable by the State.                                  
  The effective date of the                                           
  regulation/document shall,                                          
  whenever possible, be indicated in                                  
  the document itself.                                                

  5\. Evidence that the State        5\. Letter from Kathleen A.      X
  followed all of the procedural     McGinty, Secretary of the        
  requirements of the State\'s laws  Pennsylvania Department of       
  and constitution in conducting and Environmental protection dated   
  completing the adoption/issuance   September 25, 2006. Copy of      
  of the plan.                       public hearing notices.          

  6\. Evidence that public notice    6\. Copy of notice printed in    X
  was given of the proposed change   the July 31^st^ and August 1^st^ 
  consistent with procedures         and 2^nd^ 2006 editions of [The  
  approved by EPA, including the     Philadelphia Daily               
  date of publication of such        News.]{.underline}.              
  notice.                                                             

  7\. Certification that public      7\. Letter from Kathleen A.      X
  hearings were held in accordance   McGinty, Secretary of the        
  with the information provided in   Pennsylvania Department of       
  the public notice and the State\'s Environmental protection dated   
  laws and constitution, if          September 25, 2006.              
  applicable.                                                         

  8\. Compilation of public comments 8\. No comments were received.   
  and the State\'s response thereto.                                  
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**Technical Materials**

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  **EPA REQUIREMENT**                 **STATE SUBMITTAL**                **(X)**
  ----------------------------------- ---------------------------------- ---------
  1\. Identification of all regulated 1\. Section 2 of the certification X
  pollutants affected by the plan.    identifies that VOC and NOx RACT   
                                      rules are the subject of the       
                                      certification.                     

  2\. Identification of the locations 2\. The certification covers all   X
  of affected sources including the   the sources in the Philadelphia    
  EPA attainment/nonattainment        County portion of the              
  designation of the locations and    Philadelphia-Wilmington-Atlantic   
  the status of the attainment plan   City 8-hour ozone nonattainment    
  for the affected area(s).           area..                             

  3\. Quantification of the changes   3\. Revision certifies existing    X
  in plan allowable emissions from    RACT rules in the SIP. No change   
  the affected sources; estimates of  in emissions is expected.          
  changes in current actual emissions                                    
  from affected sources or, where                                        
  appropriate, quantification of                                         
  changes in actual emissions from                                       
  affected sources through                                               
  calculations of the differences                                        
  between certain baseline levels and                                    
  allowable emissions anticipated as                                     
  a result of the revision.                                              

  4\. The State\'s demonstration that 4\. Not required (N/R) for RACT.   X
  the national ambient air quality    RACT is setting emission limits    
  standards, prevention of            based upon technological &         
  significant deterioration           economic feasibility               
  increments, reasonable further      considerations.                    
  progress demonstration, and                                            
  visibility, as applicable, are                                         
  protected if the plan is approved                                      
  and implemented.                                                       

  5\. Modeling information required   5\. Not required for RACT. RACT is X
  to support the proposed revision,   setting emission limits based upon 
  including input data, output data,  technological & economic           
  models used, ambient monitoring     feasibility considerations.        
  data used, meteorological data                                         
  used, justification for use of                                         
  offsite data (where used), modes of                                    
  models used, assumptions, and other                                    
  information relevant to the                                            
  determination of adequacy of the                                       
  modeling analysis.                                                     

  6\. Evidence, where necessary, that 6\. Air Management Regulations     X
  emission limitations are based on   (AMRs) ) codified at 40 CFR        
  continuous emission reduction       52.2020(3): AMR V §II, AMR III.,   
  technology.                         AMR V. §IV.; AMR V. §V., AMR V.    
                                      §VI.; AMR V. § VII., AMR V.        
                                      §VIII.; AMR V. §X., AMR V. § XI.;  
                                      AMR V. §XII., AMR V. §XIII.;       
                                      Pennsylvania regulations codified  
                                      at 40 CFR 52.2020(c)(1): 25 Pa     
                                      Code §§129.51, 129.52, 129.55,     
                                      129.56, 129.57, 129.58, 129.59,    
                                      129.60, 129.61, 129.62, 129.63,    
                                      129.64, 129.65, 129.67, 129.68,    
                                      129.69, 129.71, 129.72, 129.73,    
                                      129.75, 129.101-107; and the       
                                      source specific RACT               
                                      determinations codified at 40 CFR  
                                      52.2020(d)(1) (Philadelphia County 
                                      Facilities).                       

  7\. Evidence that the plan contains 7\. Revision certifies existing    X
  emission limitations, work practice RACT rules in the SIP. See, for    
  standards and                       example, Air Management            
  recordkeeping/reporting             Regulations (AMRs) codified at 40  
  requirements, where necessary, to   CFR 52.2020(3) such as AMR V §II,  
  ensure emission levels.             AMR III., AMR V. §IV.; AMR V. §V., 
                                      AMR V. §VI.; AMR V. § VII., AMR V. 
                                      §VIII.; AMR V. §X., AMR V. § XI.;  
                                      AMR V. §XII., AMR V. §XIII.;       
                                      Pennsylvania regulations codified  
                                      at 40 CFR 52.2020(c)(1): 25 Pa     
                                      Code §§129.51, 129.52, 129.55,     
                                      129.56, 129.57, 129.58, 129.59,    
                                      129.60, 129.61, 129.62, 129.63,    
                                      129.64, 129.65, 129.67, 129.68,    
                                      129.69, 129.71, 129.72, 129.73,    
                                      129.75, 129.101-107; and the       
                                      source specific RACT               
                                      determinations codified at 40 CFR  
                                      52.2020(d)(1) (Philadelphia County 
                                      Facilities).                       

  8\. Compliance/enforcement          8\. Ditto                          X
  strategies, including how                                              
  compliance will be determined in                                       
  practice.                                                              

  9\. Special economic and            9\. Not applicable (N/A).          X
  technological justifications                                           
  required by any applicable EPA                                         
  policies. (If a policy is not                                          
  appropriate, explain why.)                                             

  10\. A Section 107 request must be  10\. Not a section 107 request.    X
  accompanied by a maintenance plan                                      
  demonstrating maintenance to the                                       
  relevant NAAQS for at least 10                                         
  years after redesignation.                                             
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