SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST (in accordance with 40 CFR Part 51

- App. V)

SIP Submitted by: Pennsylvania Department of Environmental Protection

Date Submitted: September 9, 2015 Subject: Allegheny County’s Ado ption of Control Techniques Guidelines for Four Industry Categories for Control of Volatile

Organic Compound Emissions

Completeness Review Completed by: Irene Shandruk Date Completed: September 17 , 201 5

Administrative Materials

ACCEPTABLE

EPA REQUIREMENT STATE SUBMITTAL (X)

1. A formal letter of submittal from the Governor or his designee, requesting EPA approval of the plan or revision thereof. 1. Letter dated September 9, 2015 from John Quigley , Secretary, Pennsylvania Department of Environmental Protection to Shawn M. Garvin, Regional Administrator. X

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 ha s submitted evidence that the regulation was approved by the Board of Health on November 5, 2014 , enacted by County Council on May 5 , 201 5 , approved and signed by the Allegheny County Chief Executive on May 8 , 201 5 , and became

effective on June 19 , 201 5

. X

3. Evidence that the State has the necessary legal authority under State law to adopt and implement the plan. 3. Allegheny County Health Department (ACHD) has legal authority under Local Health Administration Law, Act 315 of August 24, 1951, P.L. 1304. ACHD has an air pollution control program that has been approved by PADEP in accordance with

Section 12 of the Air Pollution Control Act. XEPA REQUIREMENT STATE SUBMITTAL (X)

4. A copy of actual regulation, or document submitted for approval and incorporation by reference into the plan, including 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, dated by the appropriate State official indicating that it is fully enforcea ble by the State. The effective date of the regulation/document shall, whenever possible,

be indicated in the document itself. 4. A copy of the regulation , with effective date of June 19, 2015,

w as submitted. Furthermore, a certification of approval and adoption of the regulations, dated August 8, 2015 , was submitted. X

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. Co ver letter transmitting the SIP revision dated September 9

, 201 5. C ertification of public hearing notice. X

6. Evidence that public notice was given of the proposed change consistent with procedures approved by EPA, including the date of publication o f such notice. 6. Notice of public hearing and public comment period was published in the Pittsburgh Post

- Gazette on September 1 0, 201 4

. X

7. Certification that public hearings were held in accordance with the information provided in the public notice a nd the State's laws and constitution, if applicable. 7. Certification of Public Hearing held on October 14 , 201 4 was provided

. X

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

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. X

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. Allegheny County in the State of Pennsylvania

X

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

c alculations 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 m anufacturing materials in Allegheny C ounty. X

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 consists of an amendment to ACHD Rules and Regulations, Article XXI, Air Pollution Control Sections

2105. 86. The revision will reduce emissions of VOCs from fiberglass boat manufacturing material in Allegheny County, which will aid in the (1) attainment of the 8

- hour ozone standard, and (2) improvement of the ambient air quality in Allegheny County. X

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. XEPA REQUIREMENT STATE SUBMITTAL (X)

6. Evidence, where necessary, that emission limitations are based on continuous emission reduction technology. 6. The plan established requirements to limit VOCs from fibergl ass boat manufacturing material in Allegheny County. X

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 requi rements to limit VOCs from fiberglass boat manufacturing material in Allegheny County. 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 Allegheny County. X

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. X

10. A Se ction 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. X