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: February 26, 2013

Subject: Commercial Fuel Oil Sulfur Limits for Combustion Units

Completeness Review /s/

Completed by: Jacqueline Lewis

Date Completed: March 15, 2013

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 February 25, 2013, from Micheal L. Krancer,

Secretary PADEP to Shawn Gavin, Regional Administrator 

US EPA, Region 3. 

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. Letter dated February 25, 2013, from Micheal L. Krancer, 

Secretary PADEP to Shawn Gavin, Regional Administrator 

US EPA, Region 3 and a copy of the amendments to 25 Pa. 

Code Chapters 121, 123 and 139 for Commercial Fuel Oil 

Sulfur Limits for Combustion Units, dated February 9, 2013.

X

3. Evidence that the State has the necessary legal authority under 

State law to adopt and implement the plan.

3. Legislative authority for the Pennsylvania air quality 

program relating to the responsibilities in the CAA is codified

in the Pennsylvania Air Pollution Control Act, 35 P.S. 

§§4001-4015 (APCA), including in section 4 of the APCA, 

which give the PADEP the power and duty to implement the 

provisions of the CAA in the Commonwealth. 35 P.S. 

§§4004(1).

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, 

4. A copy of the amendments to 25 Pa. Code Chapters 121, 

123 and 139 for Commercial Fuel Oil Sulfur Limits for 

Combustion Units, dated February 9, 2013.

X
EPA REQUIREMENT STATE SUBMITTAL (X)

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.

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. All of the necessary documentation was included in the 

submittal. A transmittal letter dated February 25, 2013, from 

Micheal L. Krancer, Secretary PADEP to Shawn Gavin, 

Regional Administrator US EPA, Region 3; a copy of the 

amendments to 25 Pa. Code Chapters 121, 123 and 139 for

Commercial Fuel Oil Sulfur Limits for Combustion Units, 

dated February 9, 2013; Hearing notice published in the 

Saturday, September 5, 2009 edition of the Pennsylvania 

Bulletin [39 Pa. B. 5278]; and a copy of the affidavit of 

publication and of the public notice. Second comment period 

announced in the Pennsylvania Bulletin [42 Pa. B. 3596] on 

June 23, 2012 taking comments until July 23, 2012.

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. Proof of Publication of Public Hearing notice published in 

the Saturday, September 5, 2009 edition of the Pennsylvania 

Bulletin [39 Pa. B. 5278]. Second comment period 

announced in the Pennsylvania Bulletin [42 Pa. B. 3596] on 

June 23, 2012 taking comments until July 23, 2012.

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. The Comment and Response document indicated that 

three public hearings were held at the following locations: 

October 26, 2012 in Harrisburg, PA; October 27, 2010 in 

Cranberry Township, PA; and October 28, 2010 in 

Norristown, PA.

X

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

thereto.

8. Two comment and response documents were submitted 

from both public comment periods.

X

 Technical Materials

1. Identification of all regulated pollutants affected by the plan. 1. SO2 X
EPA REQUIREMENT STATE SUBMITTAL (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. Statewide 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 of 

the revision.

3. NA 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. NA 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. NA X

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

on continuous emission reduction technology.

6. NA X

7. Evidence that the plan contains emission limitations, work 

practice standards and recordkeeping/reporting requirements, 

where necessary, to ensure emission levels.

7. 25 PA Code Chapter 123. X

8. Compliance/enforcement strategies, including how compliance 

will be determined in practice.

8. 25 PA Code Chapter 123. X

9. Special economic and technological justifications required by 

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

explain why.)

9. NA X
EPA REQUIREMENT STATE SUBMITTAL (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. NAX