UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION Ill 1650 Arch street Philadelphia, Pennsylvania 19103-2029



### The Honorable John Quigley, Acting Secretary Pennsylvania Department ofEnvironmental Protection Rachel Carson State Office Building 400 Market Street Harrisburg, PA 17105 Dear Secretary Quigley: OnJanuary 21, 2015, the U.S. Environmental Protection Agency (EPA) received a revision to the Commonwealth ofPennsylvania's State ImplementationPlan (SIP) dated January 15, 2015 from the Pennsylvania Department ofEnvironmental Protection (PADEP). The SIP revision consists ofan 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 ofProposed Rulemaking (NPR) action. Ifmembers ofyour staffhave any questions, they may direct them to Ms. Emlyn Velez-Rosa, Office ofAir Program Planning, at (215) 814-2038 or at velez-rosa.emlyn@epa.gov. She is the principal contact for this rulemaking. Sincerely,

# ~V\CA...~ DianaEsher, Director Air Protection Division

cc: Joyce E. Epps, Director, Air Quality Bureau, PADEP Kirit Dalal, Chief, Air Resource Management Division, Air Quality Bureau, PADEP



## 0 Printed on I00% recycled/recyclablepaper with I00%post-consumer fiber and process chlorine free. CustomerServiceHotline: 1-800-438-2474.·SIP Submittedby: 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 ofEnvironmental 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 Velez-Rosa, Environmental Engineer March 30, 2015 Administrative Materials ACCEPTABLE



# I EPA REQUIREMENT 

# I STATE SUBMITTAL 

# I

# {~} I
1. A formal letter ofsubmittal from the Governor or his 1. A letter dated December 15, 2015 from Dana K. Aunkst, p- designee, requesting EPA approval ofthe plan or revision Acting Secretary ofthe Pennsylvania Department ofthe hereof. Environmental Protection (PADEP) to Shawn M. Garvin, EPA Regional Administrator.
2. Evidence that the State has adopted the plan in the State code 2. A copy ofthe relevant portions ofthe consent order and 

### p- or body ofregulations; 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 ofthe 

### ' ofadoption or final issuance as well as the effective date ofthe submittal

. plan, ifdifferent from the adoption/issuance date. 

### 13. Evidence that the State has the necessary legal authority 3. The Commonwealth ofPennsylvania (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 ofactual 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 ofthe 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 ofthe regulation/document shall, whenever possible, be indicated in the document itself. ,5. Evidence that the State followed all ofthe procedural 5. The submittal letter dated January 15, 2015 confirms that all 

# v**~equirements** ofthe State's laws and constitution in conducting required administrative procedures were properly followed for and completing the adoption/issuance ofthe plan. this SIP revision. A copy ofpublic hearing notice and transcript were included. 6. Evidence that public notice was given ofthe proposed 6. A copy ofnotice ofpublic hearing was included, as 

# v change consistent with procedures approved by EPA, including published on the Pennsylvania Bulletin website on July 26, he date ofpublication ofsuch notice. 2014. Evidence ofpublication ofpublic 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, ifapplicable. comments onthe proposal. The submittal also indicates that one person provided testimony during the public hearing. 8. Compilation ofpublic comments and the State's response 8. PADEP included a document compiling the public 

# v thereto. comments received and providing responses.


### Technical S**-.-...-~--** I 

### EPA REQUIREMENT STATE SUBMITTAL (..J) 1. Identification ofall regulated pollutants affected by the plan. 1. The submittal addresses lead pollution, specifically with 

## v respect the 2008 lead NAAQS. 2. Identification ofthe locations ofaffected sources including 2. The submittal consists ofa demonstration that the Lower 

### p- the EPA attainment/nonattainment designation ofthe locations Beaver Valley nonattainment area in Pennsylvaniawill attain and the status ofthe attainment plan for the affected area(s). the 2008 lead NAAQS.EPA REQUIREMENT 3. Quantification ofthe changes in plan allowable emissions from the affected sources; estimates ofchanges in current**~ctual** emissions from affected sources or, where appropriate,**~uantification** ofchanges in actual emissions from affected sources through calculations ofthe differences between certain baseline levels and allowable emissions anticipated as a result ofthe revision.**~-The** State's demonstrationthat the national ambient air quality standards, prevention ofsignificant deterioration increments, reasonable further progress demonstration, and visibility, as applicable, are protected ifthe 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 dataused, tification for use ofoffsite data (where used), modes of dels used, assumptions, and other information relevant to determination ofadequacy ofthe 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 BeaverValley 

### (-f)

nonattainment area before and after implementation ofcontrol 

### li7 measures.

4. The submittal consists ofa demonstration that the Lower Beaver Valley nonattainment area in Pennsylvania will attain the 2008leadNAAQS. The attainment demonstration includes a demonstration ofreasonable further progress (RFP). Prevention ofsignificant 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 inprojecting attainment ofthe 2008 leadNAAQS. [7



### p6. The control measures included are not related to the implementation or adoption ofemissions 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 oftheproposed control strategy to provide for attainment ofthe 2008 lead NAAQS. [7



### p-EPA REQUIREMENT STATE SUBMITTAL 

### (-..J) I 9. Special economic and technologicaljustifications required 9. Not applicable. p- I by any applicable EPA policies. (Ifa 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.