SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST

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

 SIP Submitted by: Pennsylvania Department of Environmental Protection

 Date Submitted: 9/23/11

 Subject: Pennsylvania Nonattainment SIP for PM2.5

Completeness Review 

Completed by: Gerallyn Duke

 Date Completed: 12/16/11

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. Letter dated September 23, 2011 on behalf of the 

Commonwealth of Pennsylvania from Michael L. 

Krancer, Secretary, PADEP, to Shawn M. Garvin, 

Regional Administrator, EPA Region III

X

2. Evidence that the State has adopted the plan in the State code 

or body of regulations; or issued the permit, order, or 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.

Check to see if the regulation, permit, order or consent decree 

has a sunset or expiration date. If so it is not acceptable as a 

SIP submission. 

2. Yes. PA submitted the PA Bulletin dated September 3, 

2011 which includes a copy of the regulations. Also, 

PA Bulletin states that final rulemaking was adopted

May 18, 2011 and will be effective upon publication of 

Bulletin.

X

3. Evidence that the State has the necessary legal authority 

under State law to adopt and implement the plan.

3. Yes, PA has authority to revise and implement SIP 

with EPA oversight and approval.

X

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 

4. Yes. Final regulation was submitted as part of the 

September 3, 2011 PA Bulletin which includes a 

description of changes from proposed to final form 

rulemaking. The proposed regulation was submitted as 

part of the February 6, 2011 PA Bulletin which 

indicates changes to be made to the existing approved 

X
EPA REQUIREMENT STATE SUBMITTAL (X)

by the State. The effective date of the regulation/document 

shall, whenever possible, be indicated in the document itself.

plan, where applicable. Together these documents 

indicate all changes made to the existing approved plan.

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. September 3, 2011 PA Bulletin describes procedures 

followed and appears to be in accordance with 

applicable requirements. (see under Section K findings)

X

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. Notice of public hearing was given to the public in the 

PA Bulletin (40 PA. B705) on February 6, 2010 and in 

multiple newspapers of general circulation including 

but not limited to the Allentown Morning Call, Erie 

Times News, Pittsburgh Post Gazette, Reading Eagle, 

Scranton Times-Tribune, Williamsport Sun-Gazette, 

The Patriot News, Delaware County Times, and The 

Times Leader on February 5, 2010.

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. September 3, 2011 PA Bulletin describes procedures 

followed and appears to be in accordance with 

applicable requirements. (see under Section K findings)

X

8. Compilation of public comments and the State's response 

thereto.

8. The state submittal includes a compilation of public 

comments and responses thereto.

X

 Technical Materials

1. Identification of all regulated pollutants affected by the plan. 1. Regulations regarding particulate matter less than 2.5 

micrometers (PM2.5) as regulated new source review 

(NSR) pollutants 

 X

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. Major Stationary Sources and Major Modifications 

Locating in Nonattainment Areas

 X

 

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 

3. N/A X
EPA REQUIREMENT STATE SUBMITTAL (X)

of the revision.

4. 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. 

4. The revised SIP should be the same as or equivalent to 

the revised federal NSR permitting program which, among 

other things, is intended to protect the NAAQS for PM2.5. 

The regulations will enhance the current approved program 

in Pennsylvania. 

X

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 X

6. Evidence, where necessary, that emission limitations are 

based on continuous emission reduction technology.

6. N/A X

7. Evidence that the plan contains emission limitations, work 

practice standards and recordkeeping/reporting requirements, 

where necessary, to ensure emission levels.

7. N/A X

8. Compliance/enforcement strategies, including how 

compliance will be determined in practice.

8. N/A X

9. Special economic and technological justifications required 

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

explain why.)

9. No economic impact is seen and this addition will bring 

PA DEP regulations to be consistent with the Federal 

program. This will also fulfill a needed in the program 

which was represented in a Federal Register notice dated 

May 16, 2008 – 73 FR28321

X

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 X