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 Adoption 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, 2015

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 has submitted evidence that the regulation was 

approved by the Board of Health on November 5, 2014, enacted 

by County Council on May 5, 2015, approved and signed by the 

Allegheny County Chief Executive on May 8, 2015, and became 

effective on June 19, 2015.

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.

X
EPA 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 enforceable 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,

was 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. Cover letter transmitting the SIP revision dated September 9, 

2015. Certification 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 of such notice.

6. Notice of public hearing and public comment period was 

published in the Pittsburgh Post-Gazette on September 10, 2014.

X

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 held on October 14, 2014 was 

provided.

X

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

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 in 

Allegheny County. 

 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. 

 X
EPA 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 

fiberglass 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 requirements 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 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. X