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

- App. V) SI P Submitted by : Pennsylvania Department of Environment al Protection Date Submitted: September 5 , 2014 Subject: Redesignation R equest and Maintenance Plan for the Philadelphia

- Wilmington, PA

- NJ

- DE Nonattainment Area

for the 1997 Annual and the 2006 24

- Hour Fine Particulate Matter ( PM 2.5 ) Fine Particulate Matter Standard Completeness Review Completed by : Rose Quinto Date Completed: January 15 , 2015 **Administ rative 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 l etter dated September 5 , 2014 from PADEP Sec retary 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 submitt al is a request for redesignation, accompanied by a maintenance plan, and a request for approval of the attainment ye ar 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. X4. A copy of actual regulation, or document submitted for approval and inco rporation 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 officia l 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 include s documentation showing that the State followed State procedural and administrative requirements in is suing 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 include s a copy of the n otice of public hearing and public comment period that was published in the Pe nnsylvania 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 acc ordance wi th the public notice on June 12 , 2014. Written comments were received from two parties. X

8. Compilatio n 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. Id entification of all regulated pollutants affected by the plan. 1. Chapt er 1 o f the Maintenance Plan show s that nitrogen oxides (N Ox ) , sulfur oxides ( SO 2 ), PM 2.5 , ammonia (NH 3 ), and volatile organic compounds ( VOC ) are the pollutants affected by the plan. X

2. Id entification of the locations of affected sources in cluding the EPA attainment/nonattainment designation of the locations and the status of the attainment plan for the affected area(s). 2. R ed esignation affects the Pennsylvania portion of the Philadelphia 1997 annual and 2006 24

- hour PM 2.5 nonattainment ar ea comprised of Bucks, Chester, Delaware, Montgomery

and Philadelphia Counties , PA. EPA made a Clean Data Determination that the Area had attained the 1997 annual PM 2.5 national ambient air quality standard (NAAQS ) on May 16, 2012 ; and the 2006 24

- hour PM 2.5 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 sour ces 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 provid es 2007 actual emissions from point, area, nonroad, and on

- road source categories as the attainment ye ar inventory , which may not be exc eeded 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 PM 2.5 and its precursors will not exceed the level of the attainment inventory during the period of the Maintenance Plan. Projected i nterim year 2017 and end year 2025 emissions inventories, based on permanent and enforceable measures, are below the 2007 inve ntory , 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 mod eling analy sis. 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 int erim year 2017 and end ye ar 202 5 that do not exceed the 2007 attai nment ye ar 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 i dentifie s when and what c onting ency

measures may be implemented if the Area violates or exceeds the 1997 annual and 2006 24

- hour PM 2.5 NAAQS after redesignation of the Area

. These measures are intended to expeditiously bring the A rea back in to attainment of the NAAQS

. X

9. Specia l economic and technological justifications required by any applicable EPA policies. (I f 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 w as received from PADEP on September 5 , 2014 , which shows maintenance of the 1997 annual and the 2006 24

- hour PM 2.5 NAAQ S for 10 years after redesignation (through 2025). X