SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST

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

SIP Submitted by: Pennsylvania Department of Environmental Protection

 Date Submitted: March 2, 2016

 Subject: Control of Volatile Organic Compound Emissions from Fiberglass Boat Manufacturing Materials

Completeness Review 

 Completed by: Irene Shandruk

 Date Completed: March 22, 2016

Administrative Materials ACCEPTABLE

EPA REQUIREMENT STATE SUBMITTAL (X)

1. A formal signed, stamped, and dated letter of submittal from 

the Governor or his designee, requesting EPA approval of the 

plan or revision thereof. If electing to submit a paper 

submission with a copy in electronic version, the submittal 

letter must verify that the electronic copy provided is an exact 

duplicate of the paper submission.

1. Letter dated March 2, 2016 from John Quigley, Secretary, 

Pennsylvania Department of Environmental Protection to 

Shawn M. Garvin, Regional Administrator.

2. Evidence that the State has adopted the plan in the State code 

or body of regulations; or issued the permit, order, consent 

agreement in final form. That evidence shall include the date 

of adoption or final issuance as well as the effective date of the

plan, if different from the adoption/issuance date.

2. The State has submitted evidence that the regulation was

approved and adopted into State regulations by the 

Environmental Quality Board on May 20, 2015. The 

rulemaking became effective upon publication in the 

Pennsylvania Bulletin on December 19, 2015 (45 Pa. B. 7127).

3. Evidence that the State has the necessary legal authority 

under State law to adopt and implement the plan.

3. Pennsylvania has legal authority under section 5 of the Air 

Pollution Control Act (APCA) (35 P.S. section 4005) to adopt 

and implement SIP revisions.

4. A copy of actual regulation, or document submitted for 

approval and incorporation by reference into the plan, including 

indication of the changes made (such as redline/strikethrough)

to the existing approved plan, where applicable. The 

submission shall include 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. 

4. A copy of the regulation was submitted and where 

applicable any changes to existing regulations were indicated. 

The effective date of the regulations was December 19, 2015. 
EPA REQUIREMENT STATE SUBMITTAL (X)

The effective date of any regulation/document contained in the 

submission shall, whenever possible, be indicated in the 

regulation/document itself; otherwise the State should include a 

letter signed, stamped, and dated by the appropriate State 

official indicating the effective date. If the 

regulation/document provided by the State for approval and 

incorporation by reference into the plan is a copy of an existing 

publication, the State submission should, whenever possible, 

include a copy of the publication cover page and table of 

contents.

5. Evidence that the State followed all of the procedural 

requirements of the State’s laws and constitution in conducting 

and completing the adoption/issuance of the plan.

5. Cover letter transmitting the SIP revision dated 

March 2, 2016 and certifying that the public participation 

requirements of 40 CFR section 51.102 were met. Copies and 

certification of public hearing notices were provided. A copy 

of the rule delineating that Pennsylvania met all 

adoption/issuance requirements was included.

6. Evidence that public notice was given of the proposed 

change consistent with procedures approved by EPA, including 

the date of publication of such notice.

6. Notice of public hearing and public comment period was 

published in the Patriot News, The Morning Call, Centre Daily 

Times, and Times Leader on July 17, 2014, as well as in the 

Courier Times, Delaware County Daily Times, Erie Times 

News, Pittsburgh Post-Gazette, Reading Eagle, and Scranton 

Times Tribune on July 18, 2014.

7. Certification that public hearings were held in accordance 

with the information provided in the public notice and the 

State’s laws and constitution, if applicable.

7. Certification of Public Hearing was provided in the 

March 2, 2016 submittal.

8. Compilation of public comments and the State’s response 

thereto.

8. Public comments were received. Comments and their

responses were provided in the submittal.
Technical Support

EPA REQUIREMENT STATE SUBMITTAL (X)

1. Identification of all regulated pollutants affected by the plan. 1. The submittal identifies VOCs, which are precursors of 

8-hour ozone.

2. Identification of the locations of affected sources including 

the EPA attainment/nonattainment designation of the locations 

and the status of the attainment plan for the affected area(s).

2. The Commonwealth of Pennsylvania.

3. Quantification of the changes in plan allowable emissions 

from the affected sources; estimates of 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.

3. Not applicable. The plan established requirements to limit 

VOCs from fiberglass boat manufacturing materials. 

4. The State’s demonstration that the national ambient air 

quality standards, prevention of significant deterioration 

increments, reasonable further progress demonstration, and 

visibility, as applicable, are protected if the plan is approved 

and implemented. 

4. The SIP revision amends 25 PA. Code, Chapter 129 by 

adding section 129.74. The revision also indicates that section 

129.74 supersedes the requirements of a RACT permit issued 

under sections 129.91-95. This revision will reduce emissions 

of VOCs from fiberglass boat manufacturing materials in 

Pennsylvania which will aid in the (1) attainment of the 8-hour 

ozone standard, and (2) improvement of the ambient air quality 

in Pennsylvania. 

5. Modeling information required to support the proposed 

revision, including input data, output data, models used, 

ambient monitoring 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.

5. Not applicable. No modeling demonstration was required to 

support the required revision. 

6. Evidence, where necessary, that emission limitations are 

based on continuous emission reduction technology.

6. The plan established requirements to limit VOCs from 

fiberglass boat manufacturing materials in Pennsylvania. 

7. Evidence that the plan contains emission limitations, work 

practice standards and recordkeeping/reporting requirements, 

where necessary, to ensure emission levels.

7. The plan established requirements to limit VOCs from 

fiberglass boat manufacturing materials in Pennsylvania. 
EPA REQUIREMENT STATE SUBMITTAL (X)

8. Compliance/enforcement strategies, including how 

compliance will be determined in practice.

8. The plan established requirements to limit VOCs from 

fiberglass boat manufacturing materials in Pennsylvania. 

9. Special economic and technological justifications required 

by any applicable EPA policies. (If a policy is not appropriate, 

explain why.)

9. No special justifications are required.

10. A Section 107 request must be accompanied by a 

maintenance plan demonstrating maintenance to the relevant 

NAAQS for at least 10 years after redesignation.

10. Not applicable because this is not a section 107 request.