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 5, 2014

Subject: Redesignation Request and Maintenance Plan for the Philadelphia-Wilmington, PA-NJ-DE Nonattainment Area 

for the 1997 Annual and the 2006 24-Hour Fine Particulate Matter (PM2.5) Fine Particulate Matter Standard

Completeness Review 

Completed by: Rose Quinto

Date Completed: January 15, 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. Submittal letter dated September 5, 2014 from PADEP

Secretary E. Christopher Abruzzo to EPA Region 3 Regional 

Administrator Shawn M Garvin. Submittal letter was received 

on September 9, 2014.

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. Not applicable. (Not a regulatory change - the submittal is a 

request for redesignation, accompanied by a maintenance plan, 

and a request for approval of the attainment year inventory). 

3. Evidence that the State has the necessary legal authority

under State law to adopt and implement the plan.

3. The submittal letter states that all applicable procedural 

requirements of the State’s laws and constitution were followed 

in conducting and completing the issuance of the plan.

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. Not applicable, see 2 above. 

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. The submittal includes documentation showing that the 

State followed State procedural and administrative 

requirements in issuing the plan.

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. The submittal includes a copy of the notice of public hearing 

and public comment period that was published in the

Pennsylvania Bulletin on May 10, 2014, Bucks County Courier 

Times on May 8, 2014 and in the Delaware County Daily

Times on May 9, 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. A public hearing was scheduled in accordance with the 

public notice on June 12, 2014. Written comments were 

received from two parties.

X

8. Compilation of public comments and the State's response 

thereto.

8. The submittal included a comment and response document. X
Technical Materials

EPA REQUIREMENT STATE SUBMITTAL

1. Identification of all regulated pollutants affected by the plan. 1. Chapter 1 of the Maintenance Plan shows that nitrogen 

oxides (NOx), sulfur oxides (SO2), PM2.5, ammonia (NH3), and 

volatile organic compounds (VOC) are the pollutants affected 

by the plan. 

 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. Redesignation affects the Pennsylvania portion of the 

Philadelphia 1997 annual and 2006 24-hour PM2.5

nonattainment area comprised of Bucks, Chester, Delaware, 

Montgomery and Philadelphia Counties, PA. EPA made a 

Clean Data Determination that the Area had attained the 1997 

annual PM2.5 national ambient air quality standard (NAAQS)

on May 16, 2012; and the 2006 24-hour PM2.5 NAAQS on 

January 7, 2013, thereby suspending the requirement for an 

attainment plan. 

 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. The submittal provides 2007 actual emissions from point, 

area, nonroad, and on-road source categories as the attainment 

year inventory, which may not be exceeded during the period 

of the maintenance plan. Projection inventories were 

calculated to show that the attainment year emissions level will 

be below 2007 levels.

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. PADEP submitted a demonstration that shows that 

emissions of PM2.5 and its precursors will not exceed the level 

of the attainment inventory during the period of the 

Maintenance Plan. Projected interim year 2017 and end year 

2025 emissions inventories, based on permanent and 

enforceable measures, are below the 2007 inventory, which 

assures the NAAQS is maintained. 

X

5. Modeling information required to support the proposed 

revision, including input data, output data, models used, 

ambient monitoring data used, meteorological data used, 

5. Not applicable. 
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.

6. Evidence, where necessary, that emission limitations are 

based on continuous emission reduction technology.

6. Not applicable.

7. Evidence that the plan contains emission limitations, work 

practice standards and recordkeeping/reporting requirements, 

where necessary, to ensure emission levels.

7. Based on permanent and enforceable measures, 

Pennsylvania projects emissions inventories for interim year 

2017 and end year 2025 that do not exceed the 2007 attainment 

year inventory, which demonstrate attainment throughout the 

entire maintenance period. 

 X

8. Compliance/enforcement strategies, including how 

compliance will be determined in practice.

8. The Maintenance Plan identifies when and what 

contingency measures may be implemented if the Area violates 

or exceeds the 1997 annual and 2006 24-hour PM2.5 NAAQS

after redesignation of the Area. These measures are intended to 

expeditiously bring the Area back into attainment of the

NAAQS.

 X

9. Special economic and technological justifications required 

by any applicable EPA policies. (If a policy is not appropriate, 

explain why.)

9. Not applicable. 

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. The redesignation request was accompanied by a

Maintenance Plan that was received from PADEP on 

September 5, 2014, which shows maintenance of the 1997 

annual and the 2006 24-hour PM2.5 NAAQS for 10 years after 

redesignation (through 2025). 

 X