1 

### SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST ( I n accordance with 40 CFR Part 51

- App. V)

SIP Submitted by: TCEQ

Date Submitted: May18, 2011 Subject: Regulation No. 1 1 7

– Control of Air Pollution from Nitrogen Compounds

– Lean Bur n Engines Firing Biogas 

### Completeness Review Completed by: Alan Shar; Date Completed: J uly 21, 2011

Administrative Material s

EPA REQUIREMENT STATE SUBMITTAL Acceptable ?

Y N

1. The package is sent with a formal submittal letter from the Governor or his or her designee requesting EPA's approval of the revision. 1. The SIP package is submitted with a formal letter from TCEQ

Chairman Bryan W. Shaw to EPA Region 6. Y

2. Evidence is included that the State h as adopted the revision in the State code or body of regulations, or that the State has issued the permit, order, consent agreement (hereafter document) in final form. This evidence would include effective date of revision, if different from adoption/iss uance date. 

### 2

. State Date of adoption or final issuance: April 20, 2011 (See May 6, 2011 issue of the Texas Register final rule )

. Final Rule effective date at the State Level: May 15, 2011

. Y

3. Evidence is included that the State has necessary legal aut hority under State law to adopt and implement the revision, e.g., a citation of the appropriate State authority. 3

. See the Order of Adopting Amended Rules and Revisions to the SIP by TCEQ Chairman Bryan W. Shaw for the State Docket

# 20 1 0

- 1 152

- R UL dated A pril 29, 2011

. Y

4. A copy is included of the actual regulation or document submitted for approval and incorporation by reference into the SIP including an indication of the changes made to the existing approved plan where applicable. The

submittal shal l be a copy of the official State regulation document signed, stamped, and 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 i n the document itself. 4

. Not an IBR, The submittal shall be a copy of the official State regulation document signed, stamped, and dated by the appropriate State official indicating that it is fully enforceable by the State, and the effective date of the r ule is Final Rule effective

date at the State Level: 

### May 15, 2011

. Y

5. Evidence is included that the State followed all the procedural requirements of its laws and/or its constitution in the conducting and completing the adoption/issuance of the plan. This evidence may be: a checklist of required steps; a copy of the requirements with each step clearly identified; or other appropriate documentation. 5 . The Docket # 2010

- 1152

- RUL stamp

- dated April 29, 2011 indicates that TCEQ has followed all the proced ural requirements. Y2 EPA REQUIREMENT STATE SUBMITTAL Acceptable ?

Y N

6. Evidence is included that public notice was given of the proposed changes consistent with the procedures approved by EPA, including the date of publication of such notice, (e.g., notarized or certified copies of any public

notices published in newspapers). (The notice should be at least 30 days prior to the public hearing(s). 6 . Copy of the public notice, proof of publications, proof of public hearing , Agenda for the public hearing, and the Bryan W.

Shaw ‘s cover letter, TCEQ Chai rman, were included as components of the SIP submittal. Y

7. A certification is included indicating that public hearing(s) was/were held in accordance with the information provided in the public notice(s) and the State's laws and constitution, if applic able. 7 . See the section labeled as Notice and Proposal in the 2 011 SIP submittal (the “20 11 " here refers to the year that SIP submittal was received in the EPA R6 office and is stamp

- dated by the R6's Air Planning Section: May 23, 2011 ). Y

8. A compilat ion of public comments and the State's response is included 8 . See the section labeled as Testimony in the 20 11 SIP submittal. [The rule project number 2010

- 048

- 117

- EN has the following characteristics: Date Adopted: April 20, 2011, Date

Filed with the Sec retary of State: April 22, 2011 , Date Published

in the Texas Register : May 6, 2011 , and Date Effective at State Level: May 15, 2011 ]

. Y3 Technical Materials

EPA REQUIREMENT STATE SUBMITTAL Acceptable

?

Y N

1. Identification of all regulated pollutants affected by the revision is

included. 1 . The pollutant of concern is NOx. Y

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) is included. 2 . The submittal concerns 30 TAC Chapter 117, and affects all

m inor sources of NOx in the DFW 1997 8

- hour nonattainment

area. Y

3. Quantification of the changes in SIP allowab le emissions from the affected sources is included. (Examples include estimates of changes in current actual emissions from affected sources and/or, where appropriate, quantification of changes in actual emissions from affected sources through

calculation s of the differences between certain baseline levels and allowable emissions anticipated if the revisions were approved.) 3

. The submittal concerns 30 TAC Chapter 117, and should assist in bringing the area into ozone attainment. Y

4. Demonstration is included that the NAAQS/PSD increments/RFP demonstration and visibility as applicable, would be protected if the revision were approved and implemented. 4 . The submittal concerns 30 TAC Chapter 117, and PSD, RFP, visibility are not applicable here. Y

5

. Is there a fully approved maintenance plan for the primary ambient air quality standards for at least 10 years as required by § 175A of the Clean

Air Act? 5 . The submittal concerns 30 TAC Chapter 117, and maintenance plan per §175A of the Clean Air Act i s not applicable here Y

6. Are contingency measures included? 6 . The submittal concerns 30 TAC Chapter 117, and contingency measures do not apply here. Y

7. Modeling information required to support the propose revision, including input data, output data, models used, justification of model(s) selected, 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

ade quacy of the modeling analysis as needed. 7 . The submittal concerns 30 TAC Chapter 117, and modeling input, output, models used, data, ambient monitoring, justifications, and such information do not apply here. Y4 EPA REQUIREMENT STATE SUBMITTAL Acceptable

?

Y N

8. Evidence is included where necessary, that emission limitations are based on continuous emission reduction technology (e.g., add

- on controls, industrial/process equipment designs, reformulated materials, etc.). 8

. The submittal concerns 30 TAC Chapter 117, lean burn engines firing on landfill or biogases. No reformulated materials apply

here. Y

9. Evidence is included indicating that a SIP revision contains the following

to ensure stated emission levels: emission limitations, work practice standards, and recordkeeping/reporting requ irements 9 . S ection of interest is 117.2110(a) of this rule and concerns emission specification for 8

- hour attainment demonstration within

the DFW area

. Y

10. Compliance/enforcement strategies including how compliance will be determined in practic e (including at what frequency). 10 . Compliance is determined based on the June 1, 2007 date. The source or operator has the burden to demonstrate they met all o f the applicable requirements. CEMS, PEMS, or Alternate Method of Compliance are the tools/stra tegies for verifying compliance plans and enforcement purposes. Y

11. Evidence is included as appropriate, special economic and technological justifications are included per applicable EPA policies or an explanation why such justifications are not neces sary should be included. For example, the following types of request may require such justification: Alternative RACT, Long

- term averaging VOC emission limits, Plant wide Averaging. 11 . State has certified that their NOx control methods represent

RACT or better for ozone pollution control purpose. Special technological justifications are not applicable here since the contaminants such as chlorine, silicon, and sulfur could affect the performance of the catalyst.

. Y

Conclusion:

__ X

_ T he proposed SI P action meets completeness criteria.

_____ The proposed SIP action does not meet completeness criteria.5 

### SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST ( I n accordance with 40 CFR Part 51

- App. V)

SIP Submitt ed by: TCEQ

Date Submitted: February 2, 2010 Subject: Regulation No

. 117 Control of Air Pollution from Nitrogen Compounds

– Low Temperature Drying and Curing Ovens 

### Completeness Review Completed by: Alan Shar ; Date Completed: June 15, 2010

Administrati ve Materials

EPA REQUIREMENT STATE SUBMITTAL Acceptable?

Y N

1. The package is sent with a formal submittal letter from the Governor or his or her designee requesting EPA's approval of the revision. 1. The SIP package is submitted with a formal letter from TCEQ

Chairman Bryan W. Shaw to EPA Region 6. Y

2. Evidence is included that the State has adopted the revision in the State code or body of regulations, or that the State has issued the permit, order, c onsent agreement (hereafter document) in final form. This evidence would include effective date of revision, if different from adoption/issuance date. 

### 2. State Date of adoption or final issuance: January 13,

2010 (See January 29, 2010 issue of the Texas Register

final rule ) . Final Rule effective date at the State Level: February 4, 2010

. Y

3. Evidence is included that the State has necessary legal authority under State law to adopt and implement the revision, e.g., a citation of the appropriate State aut hority. 3

. See the Order of Adopting Amended Rules and Revisions to the SIP by TCEQ Chairman Bryan W. Shaw for the State Docket

# 200 9

- 033

- R UL dated January 15, 2010. Y

4. A copy is included of the actual regulation or document submitted for approval and incorporation by reference into the SIP including an indication of the changes made to the existing approved plan where applicable. The submittal shall be a copy of the official State regulation document signed, stamped, and dated by the appropriate Stat e 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. 4

. Not an IBR, The submittal shall be a copy of the official State regulation doc ument signed, stamped, and dated by the appropriate State official indicating that it is fully enforceable by the State, and the effective date of the rule is Final Rule effective

date at the State Level: February 4, 2010

. Y

5. Evidence is included that the State followed all the procedural requirements of its laws and/or its constitution in the conducting and completing the adoption/issuance of the plan. This evidence may be: a checklist of required steps; a copy of the requirements with each step

clea rly identified; or other appropriate documentation. 5. The Docket # 2009

- 0338

- RUL stamp

- dated January 15, 2010 indicates that TCEQ has followed all the procedural requirements. Y6 EPA REQUIREMENT STATE SUBMITTAL Acceptable?

Y N

6. Evidence is included that public notice was given of the proposed change s consistent with the procedures approved by EPA, including the date of publication of such notice, (e.g., notarized or certified copies of any public notices published in newspapers). (The notice should be at least 30 days prior to the public hearing(s). 6. Copy of the public notice, proof of publications, proof of public hearing , Agenda for the public hearing, and the Bryan W.

Shaw ‘s cover letter, TCEQ Chairman, were included as components of the SIP submittal. Y

7. A certification is included indica ting that public hearing(s) was/were held in accordance with the information provided in the public notice(s) and the State's laws and constitution, if applicable. 7. See the section labeled as Notice and Proposal in the 2 010 SIP submittal (the “20 10 " here refers to the year that SIP submittal was received in the EPA R6 office and is stamp

- dated by the R6's Air Planning Section: February 8, 2010 ). Y

8. A compilation of public comments and the State's response is included 8. See the section labeled as Test imony in the 20 10 SIP submittal. [The rule project number 200 9

- 0 23

- 117

- EN has the following characteristics: Date Adopted: January 13, 2010 , Date

Filed with the Sec retary of State: January 15, 2010, Date

Published in the Texas Register : January 29, 2010 , a nd Date

Effective at State Level: February 4, 2010 ]

. Y7 Technical Materials

EPA REQUIREMENT STATE SUBMITTAL Acceptable

?

Y N

1. Identification of all regulated pollutants affected by the revision is

incl uded. 1. The pollutant of concern is NOx. Y

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) is included. 2. The submittal concerns 30 TAC Chapter 117, and affects low temperature drying or curing ovens in the fiberglass and fiber mat manufacturing operations within the DFW area. Y

3. Quantification of the changes in SIP allowable emissions from the

affected sourc es is included. (Examples include estimates of changes in current actual emissions from affected sources and/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 if the revisions were approved.) 3. The submittal concerns 30 TAC Chapter 117, and include emission specifications of NOx when resin or other additives are used in this category of manufacturing. The c hange in the SIP is

estimated to be approximately 0.1 tons per day (tpd) of NOx

. Y

4. Demonstration is included that the NAAQS/PSD increments/RFP demonstration and visibility as applicable, would be protected if the revision were approved and implemented

. 4. The submittal concerns 30 TAC Chapter 117, and PSD, RFP, visibility are not applicable here. Y

5. Is there a fully approved maintenance plan for the primary ambient air quality standards for at least 10 years as required by § 175A of the Clean

Air Act? 5. The submittal concerns 30 TAC Chapter 117, and maintenance plan per §175A of the Clean Air Act is not applicable here Y

6. Are contingency measures included? 6. The submittal concerns 30 TAC Chapter 117, and contingency measures do not apply her e. Y

7. Modeling information required to support the propose revision, including input data, output data, models used, justification of model(s) selected, ambient monitoring data used, meteorological data used, justification for use of offsite data (whe re used), modes of models used, assumptions, and other information relevant to the determination of adequacy of the modeling analysis as needed. 7. The submittal concerns 30 TAC Chapter 117, and modeling input, output, models used, data, ambient monitoring

, justifications, and such information do not apply here. Y

8. Evidence is included where necessary, that emission limitations are based on continuous emission reduction technology (e.g., add

- on controls, industrial/process equipment designs, reformulate d materials, etc.). 8

. The submittal concerns 30 TAC Chapter 117, and emission specification from low temperature drying and curing ovens.

Reformulat ed materials do not apply here. Y8 EPA REQUIREMENT STATE SUBMITTAL Acceptable

?

Y N 9. Evidence is included indicating that a SIP revision contains the following

to ensure stated emission levels: e mission limitations, work practice standards, and recordkeeping/reporting requirements 9 . S ection of interest is 117.403(a)(12) and concerns exemptions under 117.403 for the low temperature drying and curing ovens

within DFW 8

- hour ozone nonattainm ent area. Y

10. Compliance/enforcement strategies including how compliance will be determined in practice (including at what frequency). 10. Compliance is determined based on the June 1, 2007 date. The source or operator has the burden to demonstrate t hey met all o f the applicable requirements. Y

11. Evidence is included as appropriate, special economic and technological justifications are included per applicable EPA policies or an explanation why such justifications are not necessary should be inclu ded. For example, the following types of request may require such justification: Alternative RACT, Long

- term averaging VOC emission limits, Plant wide Averaging. 11. State has provided reasons that generated thermal NOx from curing and addition of resins are too small to render themselves to adoption of post combustion NOx control techniques.

. Y

Conclusion:

__ X

_ T he proposed SIP action meets completeness criteria.

_____ The proposed SIP action does not meet completeness criteria

.