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 Technology (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 

designee, 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 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. 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. “This 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, control, 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 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. 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 emissions 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. 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. 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 Harrisburg Patriot News, the Philadelphia Inquirer, the 

Pittsburgh Post-Gazette, the Reading Eagle, the Scranton TimesTribune, the Wilkes-Barre Times Leader, and the Williamsport SunGazette
EPA 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, Sealants, 

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 through 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 deterioration 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 a 
EPA 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 proposed 

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 determination 

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 technology.

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), 

§129.67b(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, §129.67a(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 applicable 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 relevant NAAQS for at 

least 10 years after redesignation.

10. N/A. This is not a section 107 redesignation request.