June 27, 2014 

Shawn M. Garvin 

Regional Administrator 

U.S. Environmental Protection Agency, Region III 

1650 Arch Street (Mail Code: 3RAOO) 

Philadelphia, PA 19103-2029 

Dear Mr. Garvin: 

RECEIVED 

JUL- 1 2014 

Division Director (3AP00) 

On June 25, 2012, the Department of Environmental Protection (DEP) submitted for approval a 

State Implementation Plan (SIP) pertaining to amendments to the Allegheny County Health 

Department (ACHD) Rules and Regulations, Article XXI, Air Pollution Control, relating to its 

NonattainmentNew Source Review (NNSR) regulations in Sections 2102.04,2102.06, and 

2102.08. This revision is identified as Revision 66 for ACHD's internal tracking. 

The DEP is modifying its request for approval ofthe ACHD NNSR regulations as a SIP revision 

by withdrawing the following specific language from the portions of Allegheny County's revised 

regulations for New Source Review, Article XXI, Section 2102.06, which are before EPA for 

action pursuant to Section 11 O(k) of the Clean Air Act: 

"Additions, revisions, or deletions to such regulations by the Commonwealth are 

incorporated in this Subsection and are effective on the date established by the state 

regulation, unless otherwise established by regulation under this Article." 

Under the modified request, the above cited language remains part of ACHD's New Source 

Review regulations, but is not a part of the SIP revision subject to EPA review. The 

modifications are shown in the enclosure to this letter. 

We look forward to your expeditious action on this SIP revision. Should you have questions or 

need additional information, please contact Joyce E. Epps, Director ofthe Bureau of Air Quality, 

by e-mail atjeepps@pa.gov or by telephone at 717.787.9702. You may also contact 

Jayme Graham, Manager, ACHD Air Quality Program, by e-mail atjgraham@achd.net or by 

telephone at 412.578.8103. 

Sincerely, 

L cJ2-__A-O-'-!'\ 

E. Christopher Abruzzo 

Secretary 

Enclosure 

Rachel Carson State Office Building 1 P.O. Box 2063 1 Harrisburg, PA 17105-2063 

717.787.2814 02/. Printed on Recycled Paper~() www .depweb.pa .gov 

COUNTY OF 

Ms. Joyce Epps, Director 

Bureau of Air Quality 

RICH FITZGERALD 

COUNTY EXECUTIVE 

May 13,2014 

Department of Environmental Protection 

Rachel Carson Building 

400 Market Street 

P 0 Box 8468 

Harrisburg, P A 17105-8468 

Dear Ms. Epps: 

ALLEGHENY 

The purpose of this letter is to request your assistance with an action pending before the U.S. 

Environmental Protection Agency (EPA) concerning the State Implementation Plan (SIP) 

Revision for the Allegheny County Health Department's New Source Review regulation. 

On June 25, 2012, the Pennsylvania Department ofEnvironmental Protection submitted a SIP 

revision to EPA Region III on behalf of ACHD incorporating Pennsylvania's New Source 

Review regulations by reference. 

EPA has indicated that the language set forth below, which may be found in this SIP revision, is 

inconsistent with EPA's procedures for SIP revisions set forth at 40 C.F.R. §§51.103-105 and is, 

therefore, inconsistent with the Clean Air Act : 

"Additions, revisions, or deletions to such regulations by the Commonwealth are 

incorporated in this Subsection and are effective on the date established by the state 

regulations, unless otherwise established by regulation under this Article." 

With this Wlderstanding, Allegheny CoWlty is requesting that you seek the Secretary's 

concurrence and signature in a letter to the EPA Region III Administrator which withdraws this 

specific language from the portions of Allegheny County's revised regulations for New Source 

Review, Article XXI, Section 2102.06, which are before EPA for action pursuant to Section 

11 O(k) of the Clean Air Act. Withdrawal of this language will clarify that, although the above 

cited language remains part of ACHD's New Source Review regulations, such language is not a 

part of ACHD's SIP submittal that is subject to EPA review. The required changes are shown on 

the attachment to this letter. 

KAREN HACKER. MD. MPH, DIRECTOR 

ALLEGHENY COUNTY HEALTH DEPARTMENT 

955 RIVERMONT DRIVE • PITTSBURGH, PA 1 5207 

PHONE (4 1 2) 687-ACHD (2243) • FAX (41 2) 578-8325 • WWW.ACHD.NET 

JAYME GRAHAM, MANAGER. AIR QUALrTY PROGRAM 

ALLEGHENY COUNTY HEALTH DEPARTMENT 

301 39"~ STREET • PITTSBURGH, PA 1 5201 

PHONE C4 1 2) 57&81 03 • FAX (41 2) 578-81 44 • HTTPj_LWY.YYU> .. C_t:1Q,NUL:AlB./.l_N_Q_QS.l'.!:t!:.tf 
EPA request prompt action so that final action may be taken on the SIP revision. 

Thank you for your assistance in this matter. 

cc: Kirit Dalal 

Steve Hepler 

Enclosures: 

• Attachment 

Sincerely, 

q_~~~o- Jayme Graham, Manager 

Air Quality Program 

• Suggested Secretary letter w/Attaclunent 
Under §2102.06, "Major Sources Locating in or Impacting a Nonattainment Area:" 

• At Paragraph b.l, "Conditions for Approval," revise as follows: 

b. Conditions for Approval. The Department shall not issue an Installation Permit, or 

issue, amend, modify, or reissue a related Operating Permit, for any source to which this Section 

applies unless the applicant demonstrates that all of the following conditions are met: 

1. Except as otherwise specifically provided unde1· this Subsection, conditions for 

approval of an installation permit shall be applied consistent with the provisions of the 

state regulation for New Source Review promulgated under the Air Pollution Control 

Act at 25 Pa. Code §127.201 through 127.205 (except 127.201(1)), which an hereby 

incorporated by reference into this Subsection. All terms used in 25 PA Code§U7.201 

through 127.205 (except 127.201(0, and defined in 25 PA Code SeCtion 121.1 are 

incorporated by reference, except as explicitly set forth herein. Additions, revisions, 

or deletions to sueh regulations by the Commcmwealth are ineorporated into this 

Subseetion and are effective on the date established by the state regulations, unless 

otherwise established by regulation under this Artiele. 

• At Subparagraph b.3.A, "Emission Offsets," revise as follows: 

34. Emission Offsets. 

The applicant shall demonstrate that it has secured eitlwf emission 

reduction credits from the state ERC registry system or emission 

reductions from eJcisting sources in the County to offset allowable 

emissions and fugitive dust emissions from the proposed new source or 

the proposed modification by at least the ratios set forth below; provided 

that, in the case of a source to which this gection applies solely because of 

a significant air quality impact in a nonattainment area, offsets resulting in 

a net air quality benefit in the affected nonattainrnent area shall be 

sufficient. 

A. Incorporation by Reference. Except as otherwise specifically 

provided under this Subsection, the state regulations for the use of 

Emission Reduction Credits and offset ratios promulgated under 

the Air Pollution Control Act at 25 Pa. Code §§127.206 through 

127.210 inclusive, are hereby incorporated by reference into this 

Subsection. All terms used in 25 PA Code 127.206 through 127.210 

inclusive, and defined in 25 P A Code Section 121.1, are 

incorporated by reference except as explicitly set forth herein. 

Additiens, re'l'isiens, et' deletiens te sueh regulatieBs bv the 

Commem"''ealth are ineon~orated inte this gubseetion and 1ue 

effeetive en the d:ate established bv the state regulations, uBless 

otherwise established bl' regulatien uad:er this Artiele. 

• At Subsection e, "Portable Facilities," revise as follows: 

e. Portable facilities. Incorporation by Reference. The state regulations 

for portable facilities under the Air Pollution Control Act at 25 Pa. 

Code §§127.212 are hereby incorporated by reference into this 

Subsection. All terms used in 25 PA Code §§127.212 and defined in 25 

P A Code Section 121.1 are incorporated by reference. Additions, 

Fevisions, oF deletions to sueh Fegulations by the Commonwealth are 

ineon:.orated into this Subseetion and aFe effeetive on the date 

established bv the state regulations, unless otherwise established by 

regulation under this Artiele. 

• At Subsection g, "Plantwide Applicability Limits (PALs), revise as follows: 

g. PLANTWIDE APPLICABILITY LIMIT (PALs) 

The Plantwide Applicability Limits (PALs) regulations in 25 Pa. Code 

§ U7.218 are hereby incorporated by reference into this Subsection. 

All terms used in 25 PA Code § 127.218 and defined in 25 P A Code 

Section 121.1 are incorporated bv reference, except as explicitly set 

forth herein. ,A..,dditions, rtwisions, or deletions to sueh regulations by 

the Commonwealth are ineoraorated into this Subseetion and are 

effeetive on the date established by the state regulations, unless 

otheFwise established by regulation under this Artiele.