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

- App. V)

SIP Submitted by: Pennsylvania Department of Environmental Protection (PADEP)

Date Submitted: August 27, 2014 Subject: Reasonably Available Control T echnology (RACT) requirements for the control of volatile organic

compound (VOC) emissions from flexible packaging printing presses, offset lithographic printing presses and letterpress printing presses, and from adhesives, sealants, primers and solvents.

Completeness Review Completed by: Maria A. Pino Date Completed: October 1, 2014

Administrative Materials ACCEPTABLE

EPA REQUIREMENT STATE SUBMITTAL (X)

1. A formal letter of submittal from the Governor or his

d esignee, requesting EPA approval of the plan or

revision thereof. 1. August 27, 2014 letter from PADEP Secretary E. Christopher Abruzzo to EPA Regional Administrator Shawn M. Garvin.

2. Evidence that the State has adopted the plan in the State code or body of regulation s; or issued the permit, order, c onsent 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/i ssuance date. 2. Final rule “ Flexible Packaging Printing Presses, Offset Lithographic Printing Presses and Letterpress Printing Presses; Adhesives, Sealants, Primers and Solvents” published in the Pennsylvania Bulletin, Vol. 44, No. 26, June 28, 2014

. “T his order was adopted by the Board at its meeting of February 18, 2014.” “ Effective

Date: This final

- form rulemaking will be effective upon publication in

the Pennsylvania Bulletin .”

The Commonwealth adopted the regulation under the authority Section 5(a )(1) of the Air Pollution Control Act (35 P.S. § 4005(a)(1), which grants the Board the authority to adopt regulations for the prevention, control, reduction and abatement of air pollution.EPA REQUIREMENT STATE SUBMITTAL (X)

3. Evidence that the State has the necessary legal authority under State law to adopt and implement the plan. 3. Section 5 of the Air Pollution Control Act (35 P. S. § 4005), which in subsection (a)(1) grants the Board the authority to adopt rules and regulations for the prevention, contro l, reduction and abatement of air pollution in this Commonwealth, and which in subsection (a)(8) grants the Board the authority to adopt rules and regulations designed to implement the Clean Air Act (CAA) (42 U.S.C.A. §§ 7401

— 7671q). 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 offic ial 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. Final rule “ Flexible Packaging Printing Presses, Offset Lithographic Printing Presses and Letterpress Printing Presses; Adhesives, Sealants, Primers and Solvents” published in the Pennsylvania Bulletin, Vol. 44, No. 26, June 28, 2014: Annex A, Title

25. Environmental Protection, Part I. Department of Environmental Protection, Subpart C. Protection of Natural Resources, Article III. Air Resources, Chapter 121. General Provisions (Definitions); Chapter 129. Standards of Sources, Sources of VOCs, §125.51 . General, §126.67. Graphic Art Systems, § 129.67a(a). Control of VOC emissions from flexible packaging printing presses, § 129.67b(a) Control of VOC emissions from offset lithographic printing presses and letterpress printing presses, §129.77 Control of emi ssions from the use or application of adhesives, sealants, primers and solvents; and Chapter 30. Standards for Products, Subchapter D. Adhesives, Sealants, Primers, and Solvents, §130.703. Exemptions and exceptions

. 5. Evide nce 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. August 27, 2014 letter from PADEP Secretary Abruzzo to EPA Regional Administrator Shawn M . Garvin in which Secretary Abruzzo certified that the Commonwealth followed all of the applicable procedural requirements of the State's laws and constitution in conducting and completing the adoption/issuance of the SIP revision. 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. Notices in 9 publications: The Allentown Morning Call, the Erie Times News, the Harris burg Patriot News, the Philadelphia Inquirer, the Pittsburgh Post

- Gazette, the Reading Eagle, the Scranton Times

Tribune, the Wilkes

- Barre Times Leader, and the Williamsport Sun

GazetteEPA REQUIREMENT STATE SUBMITTAL (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. August 27, 2014 letter from PADEP Secretary Abruzzo to EPA Regional Administrator Shawn M. Garvin in which Secretary Abruzzo certified that the public participation requirements of 40 CFR § 51.102 were met, including that public hearings were held on the dates and at the locations advertised in the proposed rulemaking notice (42 Pa. B. 779, 787). 8. Compilation of public comments and the State's response thereto. 8. Comment and Response for “Control of VOC Emissions from Flexible Packaging Printing Presses, Offset Lithographic Printing Presses and Letterpress Printing Presses, and Adhesives, Seal ants,
Primers and Solvents

Technical Support

EPA REQUIREMENT STATE SUBMITTAL (X) 1. Identification of all regulated pollutants affected by the plan. 1. VOCs , See § 129.67(a), § 129.67a(a), and § 129.67b (a).

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. statewide

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 throu gh calculations of the differences between certain baseline levels and allowable emissions anticipated as a result of

the revision. 3. N/A. The regulation established requirements to control

VOC emissions from flexible packaging printing presses, offset lithographic printing presses and letterpress printing presses, and from adhesives, sealants, primers and solvents

.

4. The State's demonstration that the national ambient air quality standards, prevention of significant det erioration increments, reasonable further progress demonstration, and visibility, as 4. The regulation was adopted pursuant to the nonattainment area requirements under §§172(c)(1), 182(b )(2)(A) and 184(b)(1)(B) of the CAA for the control of VOCs as aEPA REQUIREMENT STATE SUBMITTAL (X)

applicable, are protected if the plan is approved and implemented. precursor to ozone. Therefore, PSD increments and protection (maintenance) of NAAQS are not applicable. 5. Modeling information required to support the prop osed revision, including input data, output data, models used, ambient monitoring data used, meteorological data used, justification for use of offsite data (where used), modes of models used, assumptions, and other information relevant to the determinati on of adequacy of the modeling analysis. 5. N/A. No modeling demonstration was required to support this regulation.

6. Evidence, where necessary, that emission limitations are based

on continuous emission reduction technol ogy. 6. N/A. The regulation established requirements to control

VOC emissions from flexible packaging printing presses, offset lithographic printing presses and letterpress printing presses, and from adhesives, sealants, primers and solvents

. 7. Evidence that the plan contains emission limitations, work practice standards and recordkeeping/reporting requirements, where necessary, to ensure emission levels. 7. VOC limits under 129.67(b), § 129.67a (c), and § 129.67b (c), § 129.67 b (d). Recordkeeping requirements under § 129.51 (d), § 129.67a (e), and § 129.67b (f).

8. Compliance/enforcement strategies, including how compliance will be determined in practice. 8. § 129.51 (c) Demonstration of compliance, § 1 29.67a (d) Compliance and monitoring requirements for an

add

- on air pollution control device, and § 129.67b (e) Compliance and monitoring requirements.

9. Special economic and technological justifications required by any applic able EPA policies. (If a policy is not appropriate, explain why.) 9. N/A. No special justifications are required.

10. A Section 107 request must be accompanied by a maintenance plan demonstrating maintenance to the relevan t NAAQS for at least 10 years after redesignation. 10. N/A. This is not a section 107 redesignation request.