1

SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST

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

SIP Submitted by: TCEQ

Date Submitted: May18, 2011

Subject: Regulation No. 117 – Control of Air Pollution from Nitrogen Compounds – Lean Burn Engines Firing Biogas

Completeness Review 

Completed by: Alan Shar; Date Completed: July 21, 2011

Administrative 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, consent 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: 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 authority 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 

# 2010-1152-RUL dated April 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 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. 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 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 rule 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 procedural 

requirements.

Y
2

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 Chairman, 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 applicable.

7. See the section labeled as Notice and Proposal in the 2011 SIP 

submittal (the “2011" 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 compilation of public comments and the State's response is included 8. See the section labeled as Testimony in the 2011 SIP 

submittal. [The rule project number 2010-048-117-EN has the 

following characteristics: Date Adopted: April 20, 2011, Date 

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

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

Level: May 15, 2011] .

Y
3

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 

minor sources of NOx in the DFW 1997 8-hour nonattainment 

area. 

Y

3. Quantification of the changes in SIP allowable 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 

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 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 is 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 

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
4

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 requirements 

9. Section 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 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 they met all of 

the applicable requirements. CEMS, PEMS, or Alternate Method 

of Compliance are the tools/strategies 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 necessary 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_The proposed SIP action meets completeness criteria.

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

SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST

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

SIP Submitted 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

Administrative 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, consent 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 authority.

3. See the Order of Adopting Amended Rules and Revisions to 

the SIP by TCEQ Chairman Bryan W. Shaw for the State Docket 

# 2009-033-RUL 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 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.

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 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 

clearly 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.

Y
6

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 Chairman, 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 applicable.

7. See the section labeled as Notice and Proposal in the 2010 SIP 

submittal (the “2010" 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 Testimony in the 2010 SIP 

submittal. [The rule project number 2009-023-117-EN has the 

following characteristics: Date Adopted: January 13, 2010, Date 

Filed with the Secretary of State: January 15, 2010, Date 

Published in the Texas Register: January 29, 2010, and Date 

Effective at State Level: February 4, 2010].

Y
7

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 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 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 

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 change 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 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 

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, reformulated materials, etc.).

8. The submittal concerns 30 TAC Chapter 117, and emission 

specification from low temperature drying and curing ovens.

Reformulated materials do not apply here.

Y
8

EPA REQUIREMENT STATE SUBMITTAL Acceptable

?

Y N

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 requirements 

9. Section 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 nonattainment 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 they met all of 

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 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 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_The proposed SIP action meets completeness criteria.

 _____ The proposed SIP action does not meet completeness criteria.