SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST

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

SIP Submitted by: Pennsylvania Department of Environmental Protection on behalf of Allegheny County Health Department

 Date Submitted: January 15, 2014

 Subject: Outdoor Wood-Fired Boiler regulations

Completeness Review 

 Completed by: Ellen Schmitt

 Date Completed: 1/27/14

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. Yes, letter dated January 3, 2014 from E. Christopher 

Abruzzo, Secretary Pennsylvania Department of Environmental 

Protection to Diana Esher, Director.

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.

2. Yes, the State has submitted evidence that the regulations 

were adopted and approved in final form on May 29, 2013, 

with an effective date of June 8, 2013.

3. Evidence that the State has the necessary legal authority 

under State law to adopt and implement the plan.

3. Allegheny County Health Department has the legal 

authority to enforce laws relating to public health within 

Allegheny County under the Local Health Administration Law, 

Act 315 of August 24, 1951, P.L. 1304, as amended and 

administer a local air pollution program approved by PADEP in 

accordance with Section 12 of the Air Pollution Control Act 35 

P.S. Section 4012.

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, a letter dated January 3, 2014, transmitting the SIP 

revision including the Certification of Approval and Adoption. 

The regulations were adopted on May 2, 2012, enacted May 22, 

2013, approved May 29, 2013, and became effective on June 8, 

2013.
EPA REQUIREMENT STATE SUBMITTAL (X)

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

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

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. Yes, all of the necessary documentation was included in the 

submittal.

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. Yes, Proof of Publication provided showing that the notice 

of public hearing was published in the Pittsburg Post-Gazette 

on December 15, 2011. 

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. Yes, the signed Certification of Hearing shows that a public 

hearing was held on January 19, 2012.

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

thereto.

8. Yes, a summary of comments and responses was provided; a 

total of 42 comments were received.

Technical Support

EPA REQUIREMENT STATE SUBMITTAL (X)

1. Identification of all regulated pollutants affected by the plan. 1. This submittal consists of the adoption (incorporating by 

reference) of PADEP’s Outdoor Wood-Fired Boiler regulations 

and relevant definitions for the control of emissions of fine 

particulate matter (PM2.5).

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. N/A

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
EPA REQUIREMENT STATE SUBMITTAL (X)

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. N/A

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

6. Evidence, where necessary, that emission limitations are 

based on continuous emission reduction technology.

6. N/A

7. Evidence that the plan contains emission limitations, work 

practice standards and recordkeeping/reporting requirements, 

where necessary, to ensure emission levels.

7. The regulation provides notice and recordkeeping 

requirements at the time of sale.

8. Compliance/enforcement strategies, including how 

compliance will be determined in practice.

8. Through a response to comment ACHD states that, “The 

ACHD regularly implements effective enforcement of all 

Article XXI regulations, and expects to do the same with the 

proposed new OWB regulations.” 

9. Special economic and technological justifications required 

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

explain why.)

9. N/A

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