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SIP Submitted by: 

Date Submitted: 

SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST 

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

PA Department of Environmental Protection (PADEP) 

August 17, 2007 

Subject: Changes to the nonattainment New Source Review (NSR) regulation. This regulation amends 25 Pa. Code 

Section 121.1 (definitions) and 25 Pa. Code Chapters 127 (construction, modification, reactivation and 

operation of sources). 

Completeness Review . 

Completed by: Michelle L. Moyer 

Date Completed: October 2, 2007 

Administrative Materials ACCEPTABLE 

EPA REQUIREMENT STATE SUBMITTAL ~I 1. A formal letter of submittal from the Governor or his 1. Letter submitted August 9,2007 on behalf of the X 

~esignee, requesting EPA approval of the plan or revision Commonwealth of Pennsylvania from Kathleen A. McGinty, 

hereof. Secretary, PADEP to Donald S. Welsh, Regional 

Administrator, EPA Region m. 

12. Evidence that the State has adopted the plan in the State code 2. Yes. P A submitted the P A Bulletin dated May 19, 2007 X 

lor body of regulations; or issued the permit, order, consent which includes a copy of the regulations. Also, Bulletin states 

iagreement in final form. That evidence shall include the date that final rulemaking was adopted February 20,2007 and will 

Iof adoption or final issuance as well as the effective date ofthe be effective upon publication of Bulletin. 

!plan, if different from the adoption/issuance date. 

3. Evidence that the State has the necessary legal authority 3. Yes, PA has authority to revise and implement SIP with X 

under State law to adopt and implement the plan. EP A oversight and approval. 

4. A copy of actual regulation, or document submitted for 4. Yes. Regulation was submitted as part of the May 19, 2007 X 

approval and iQ,corporation by reference into the plan, including P A Bulletin which includes a copy of the proposed regulations. 
': ... 

EPA REQUIREMENT STATE SUBMITTAL t i(Xl . ndication 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 

iby the State. The effective date ofthe regulation/document 

shall, whenever Qossible, be indicated in the document itself. 

5. Evidence that the State followed all of the procedural 5. May 19, 2007 PA Bulletin describes procedures followed X 

equirements of the State's laws and constitution in conducting and appears to be in accordance with applicable requirements. 

~d completing the adoption/issuance, of the plan. (see under Section K findings) 

6. Evidence that public notice was given of the proposed 6. Notice of public hearing was given to the public in the X 

change consistent with procedures approved by EPA, including Pennsylvania Bulletin (36 Pa.B 7926) on Saturday, May 19, 

~e date of publication of such notice. 2007 and in multiple newspapers of general circulation 

including but not limited to the Patriot News, Morning Call, 

time Tribune from May 2nd- 4th 2006. 

7. Certification that public hearings were held in accordance 7. May 19, 2007 PA Bulletin describes procedures followed X 

~ith the information provided in the public notice and the and appears to be in accordance with applicable requirements. 

State's laws and constitution, if applicable. (see under Section K findings) 

8. Compilation of public comments and the State's response 8. The state submittal includes a compilation of public X 

hereto. comments and responses thereto. 

1. Identification of all regulated pollutants affected by the plan. 1. It addresses all current and future nonattainment areas for X 

all pollutants and special provisions are provided for the 

Moderate Ozone Non-Attainment areas that include: 

Philadelphia, Montgomery, Bucks, Chester and Delaware 

County. 

~. Identification of the locations of affected sources including 2. It addresses all current and future nonattainment areas for X 

he EPA attainmentlnonattainment designation of the locations all pollutants and special provisions are provided for the 
EPA REQUIREMENT STATE SUBMITTAL I (X) 

and the status of the attainment plan for the affected area(s). Moderate Ozone Non-Attainment areas that include: 

Philadelphia, Montgomery, Bucks, Chester and Delaware 

County. 

3. Quantification ofthe changes in plan allowable emissions 3. N/A 

from the affected sources; estimates of changes in current 

actual emissions from affected sources or, where appropriate, 

Auantification 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. 

~. The State's demonstration that the national ambient air 4. N/A 

Iquality standards, prevention of significant deterioration X 

~ncrements, reasonable further progress demonstration, and 

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

land implemented. 

5. Modeling information required to support the proposed 5. N/A 

Irevision, including input data, output data, models used, X 

ambient monitoring data used, meteorological data used, 

tiustification for use of offsite data (where used), modes of 

!models used, assumptions, and other information relevant to the 

kietermination of adequacy of the modeling analysis. 

16. Evidence, where necessary, that emission limitations are 6. The nonattainment NSR regulations require the application X 

/based on continuous emission reduction technology. ofLAER (Lowest Achievable Emissions Rates). 

7. Evidence that the plan contains emission limitations, work 7. Found in regulations, 25 Pa Code 127.20l. X 

practice standards and recordkeepinglreporting requirements, 

Iwhere necessary, to ensure emission levels. 

8. Compliance/enforcement strategies, including how 8. Found in regulations, 25 Pa Code 127.20l. X 
EPA REQUIREMENT .;. , ~ STATE SUBMITTAL ~ i (X) 

compliance will be determined in practice. 

9. Special economic and technological justifications required by 9. N/A X 

any applicable EPA policies. 

10. A Section 107 request must be accompanied by a 10. N/A X 

~aintenance plan demonstrating maintenance to the relevant 

NAAQS for at least 10 years after redesignation.