UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION Ill 

1650 Arch street 

Philadelphia, Pennsylvania 19103-2029 

The Honorable John Quigley, Acting Secretary 

Pennsylvania Department of Environmental Protection 

Rachel Carson State Office Building 

400 Market Street 

Harrisburg, PA 17105 

Dear Secretary Quigley: 

On January 21, 2015, the U.S. Environmental Protection Agency (EPA) received a revision to 

the Commonwealth of Pennsylvania's State Implementation Plan (SIP) dated January 15, 2015 from the 

Pennsylvania Department ofEnvironmental Protection (PADEP). The SIP revision consists of an 

attainment demonstration for the Lower-Beaver Valley nonattainment area for the 2008 lead national 

ambient air quality standards (NAAQS). EPA has determined that the submittal is administratively and 

technically complete, and is reviewing it to prepare a Notice of Proposed Rulemaking (NPR) action. 

If members of your staff have any questions, they may direct them to Ms. Emlyn V elez-Rosa, 

Office of Air Program Planning, at (215) 814-2038 or at velez-rosa.emlyn@epa.gov. She is the 

principal contact for this rulemaking. 

Sincerely, 

~V\CA...~ 

Diana Esher, Director 

Air Protection Division 

cc: Joyce E. Epps, Director, Air Quality Bureau, PADEP 

Kirit Dalal, Chief, Air Resource Management Division, Air Quality Bureau, P ADEP 

0 Printed on I 00% recycled/recyclable paper with I 00% post-consumer fiber and process chlorine free. 

Customer Service Hotline: 1-800-438-2474 
.
SIP Submitted by: 

Date Submitted: 

Subject: 

Completeness Review 

Completed by: 

Date Completed: 

SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST 

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

Pennsylvania Department of Environmental Protection (PADEP) 

January 21, 2015 

Attainment Demonstration for the Lower Beaver Valley Nonattainment Area for the 2008 Lead 

National Ambient Air Quality Standards (NAAQS) 

Emlyn V elez-Rosa, Environmental Engineer 

March 30, 2015 

Administrative Materials ACCEPTABLE 

I EPA REQUIREMENT I STATE SUBMITTAL I {~} I 

1. A formal letter of submittal from the Governor or his 1. A letter dated December 15, 2015 from Dana K. Aunkst, p- designee, requesting EPA approval of the plan or revision Acting Secretary of the Pennsylvania Department of the 

hereof. Environmental Protection (P ADEP) to Shawn M. Garvin, EPA 

Regional Administrator. 

2. Evidence that the State has adopted the plan in the State code 2. A copy of the relevant portions of the consent order and 

p- or body of regulations; or issued the permit, order, consent agreement entered by and between PADEP and Horseheadagreement in final form. That evidence shall include the date Monaca on July 2P\ 2012, was included as part of the ' 

of adoption or final issuance as well as the effective date of the submittal. 

plan, if different from the adoption/issuance date. 

13. Evidence that the State has the necessary legal authority 3. The Commonwealth of Pennsylvania (Pennsylvania) has the 

v under State law to adopt and implement the plan. authority to adopt, implement and revise its State 

Implementation Plan (SIP), pursuant to the Pennsylvania Air 

Pollution Control Act. 

4. A copy of actual regulation, or document submitted for 4. The submittal includes the attainment demonstration for 

~pproval and incorporation by reference into the plan, including the 2008 lead National Ambient Air Quality Standard v 

I indication of the changes made to the existing approved plan, (NAAQS), requested to be approved as a revision to the SIP. 

where applicable. The submittal shall be a copy ofthe official Changes to the proposed plan are discussed in the Response to 

State regulation/document signed, stamped, dated by the Comments document included. 
EPA REQUIREMENT STATE SUBMITTAL (..J) 

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. 

,5. Evidence that the State followed all of the procedural 5. The submittal letter dated January 15, 2015 confirms that all 

v ~equirements of the State's laws and constitution in conducting required administrative procedures were properly followed for 

and completing the adoption/issuance of the plan. this SIP revision. A copy of public hearing notice and 

transcript were included. 

6. Evidence that public notice was given of the proposed 6. A copy of notice of public hearing was included, as 

v change consistent with procedures approved by EPA, including published on the Pennsylvania Bulletin website on July 26, 

he date of publication of such notice. 2014. Evidence of publication of public hearing notice on local 

newspapers on July 25, 2014 was included. As specified in the 

notice, a public hearing was scheduled to be held on September 

3, 2014, and written comments were accepted until September 

5, 2014. 

7. Certification that public hearings were held in accordance 7. The submittal letter dated January 15, 2015 confirms that a 

v with the information provided in the public notice and the public hearing was held on September 3, 2014 to receive 

State's laws and constitution, if applicable. comments on the proposal. The submittal also indicates that 

one person provided testimony during the public hearing. 

8. Compilation of public comments and the State's response 8. P ADEP included a document compiling the public v thereto. comments received and providing responses. 

Technical S -.-...-~--

I 

EPA REQUIREMENT STATE SUBMITTAL (..J) 

1. Identification of all regulated pollutants affected by the plan. 1. The submittal addresses lead pollution, specifically with v 

respect the 2008 lead NAAQS. 

2. Identification of the locations of affected sources including 2. The submittal consists of a demonstration that the Lower p- the EPA attainment/nonattainment designation ofthe locations Beaver Valley nonattainment area in Pennsylvania will attain 

and the status of the attainment plan for the affected area(s). the 2008 lead NAAQS. 
EPA REQUIREMENT 

3. Quantification of the changes in plan allowable emissions 

from the affected sources; estimates of changes in current 

~ctual emissions from affected sources or, where appropriate, 

~uantification 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 

quality standards, prevention of significant deterioration 

increments, reasonable further progress demonstration, and 

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

and implemented. 

5. Modeling information required to support the proposed 

evision, including input data, output data, models used, 

E

bient monitoring data used, meteorological data used, 

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

dels used, assumptions, and other information relevant to 

determination of adequacy of the modeling analysis. 

6. Evidence, where necessary, that emission limitations are 

based on continuous emission reduction technology. 

7. Evidence that the plan contains emission limitations, work 

practice standards and recordkeeping/reporting requirements, 

jwhere necessary, to ensure emission levels. 

8. Compliance/enforcement strategies, including how 

!compliance will be determined in practice. 

STATE SUBMITTAL 

3. The submittal quantifies allowable and actual emissions 

from affected sources in the Lower Beaver Valley 

(-f) 

nonattainment area before and after implementation of control li7 

measures. 

4. The submittal consists of a demonstration that the Lower 

Beaver Valley nonattainment area in Pennsylvania will attain 

the 2008lead NAAQS. The attainment demonstration 

includes a demonstration of reasonable further progress (RFP). 

Prevention of significant deterioration (PSD) and visibility 

protection are not addressed in this plan. 

5. The submittal includes all relevant information to document 

air quality dispersion modeling performed in projecting 

attainment of the 2008 lead NAAQS. 

[7 

p6. The control measures included are not related to the 

implementation or adoption of emissions reduction technology .• v 

7. The plan contains emission limitations, work practice 

standards and recordkeeping/reporting requirements, where 

necessary, to ensure emission levels. 

8. Compliance strategies are provided as part ofthe proposed 

control strategy to provide for attainment of the 2008 lead 

NAAQS. 

[7 

p-
EPA REQUIREMENT STATE SUBMITTAL (-..J) I 

9. Special economic and technological justifications required 9. Not applicable. p- I 

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

explain why.) 

10. A Section 107 request must be accompanied by a 

10. Not applicable. maintenance plan demonstrating maintenance to the relevant pNAAQS for at least 10 years after redesignation.