## EPA Checklist for PM **2.5** 

## SIP Submittals **SIP submitted by: Pen**  **nsylvania Department of E**  **nvironmental Protection for the**  **Attainment Demonstration and Base Year Inventory for the Pennsylvania portion of the**  **Philadelphia -**  **Wilmington, PA -**  **NJ -**  **DE PM**  **2.5 Nonattainmen**  **t Area Date submitted: April 12, 2010**  **Purpose :**  This checklist has been prepared b y EPA staff for use in reviewing PM 2.5 SIP s ubmittals that are due to EPA by April 5, 2008, from each State having a nonattainment area designation that became effective on April 5, 2005. T his checklist is intended to summarize the requirements of Part 51 , Appendix V , “Criteria for Determining the Completeness of Plan Submissions,” and Part 51 , Subpart Z, “Provisions for Implementation of PM 2.5 Nat ional Ambient Air Quality Standards
. ” Also included are sections on the applicability requirements of Part 93, Subpart A , “ Conformity to State/Federal Implementation Plans of Transportation Plans, Programs, and Projects , ” and the compliance monitoring req uirements of Part 51 , Subpart K, “ Source Surveillance
. ” This checklist is not a regulation and does not change or substitute for an y l egal requirements of the Clean Air Act (CAA) or applicable rules. An y decisions regarding the approvability of a particu lar SIP will be made based on the requirements of the CAA and the relevant regulations. Interested parties are free to raise questions and objections to th is checklist or to its use in a particular situation. **Acronyms and Terms**  **:** CAA is Clean Air Act CA IR is Clean Air Interstate Rule EIis emissions inventory MV is motor vehicle NAA is nonattainment area NAAQS is national ambient air quality standards NH 3 is ammonia NOx is nitrogen oxide s RACM is reasonably available control measures RACT is reasonabl y available control technology RFP is reasonable further progress SIP is state implementation plan SO 2 is sulfur dioxide**Notes on use of this checklist**  **:** (1) For a ll items in the checklist with boxes under the “Completeness” column , users should mark the firs t box as “Y” (y es) , “N” (no), or “N/A” (not applicable). An “N” (no) response may indicate a deficiency

in the SI P submittal
. “Y” and “N/A” responses indicate completeness of the item in the SIP and do not reflect on approvability of the item
. The secon d box is for recording the location of the item in the SIP submittal
. (2) Several items in the checklist do not have boxes to mark under the “Completeness” column. These items are not intended as part of an initial SIP completeness check but are included to a ssist reviewers in assessing the approvability of a SIP submittal. **References :**  (1) “ E I Guidan ce ” : Emission Inventory Guidance for Implementation of Ozone and Particulate Matter National Ambient Air Quality Standards (NAAQS) and Regional Haze Regulations (Au gust 2005) ( http://www.epa.gov/ttn/chief/eidocs/eiguid/eiguidfinal_nov2005.pdf ) (2) “ Modeling Guidance ” : Guidance on Use of Models and Other Anal ys es for Demonstrating Attainme nt of Air Qualit y Goals for Ozone, PM 2.5 and Regional Haze (April 2007) ( http://www.epa.gov/ttn/scram/guidance/guide/final
- 03
- pm - rh
- guidance.pdf ) (3) “Road Dust Guidance”: Policy Guidance on the Use of the November 1, 2006, Update to AP
- 42 for Re
- entrained Road Dust for SIP Development and Transportation Conformity (August 2, 2007) (4) “110(a) Guidance” : Guidance on SIP Elements Required Under section 110(a)(1) and (2) for the 1997 8
- hour Ozone and PM2.5 National Ambient Air Quality

Standards (October 2, 2007) ( http://www.epa.gov/ttn/caaa/t1/memoranda/110a_sip_guid_fin100207.pdf ) ( http://www.epa.gov/ttn/chief/ap42/ch13/related/rel13s02_memo080207.pdf ) (5) “ PM Impl. Rule ” : Clean Air Fine Particle Implementation Rule , **72 FR 20586** ( April 25, 2007 ) ( http://a257.g.akamaitech.net/7/257/2422/01jan20071800/edocket.access.gpo.gov/2007/pdf/E7
- 6347.pdf ) (6) “Transp. Conf

. Rule ” : Transportation Conformity Rule Ame ndments for the New 8
- hour Ozone and PM 2.5 National Ambient Air Quality Standards and Miscellaneous Revisions for Existing Areas; Transportation Conformity Rule Amendments: Response to Court Decision and Additional Rule Changes, **69 FR 40004** ( July 1, 2004 ) ( http://a257.g.akamaitech.net/7/257/2422/06jun20041800/edocket.access.gpo.gov/2004/pdf/04
- 14213.pdf ) (7) “SIP Preparation Rule ”: Air Quality Imp lementation Plans; Restructuring SIP Preparation Regulations, **51 FR 40656** (November 7, 1986) (8) “C E Rule” Credible Evidence Revisions , **62 FR 8328** (February 24, 1997 ) ( http://www.epa.gov/EPA
- AI R/1997/February /Day
- 24/a4196.pdf

)**Regulatory**

**Citation Requirement**  **Completeness References**  **Y, N, or N/A Location in SIP**  

### Administrative Requirements from **Part 51, Appendix V**  **2.0. Criteria** 2.1(a) Has a letter of submittal from the governor/de signee,

requesting EPA approval of the SIP been received? Y Letter dated 04 / 1 2/10 from John H anger, Secretary , PADEP to Shawn M. Garwin, RA . 2.1(b)

Has the State provided evidence it has adopted the legall y

enforceable portions of the plan in the State c ode or body of regulations; or issued the necessary permits, orders, and consent agreements in final form? Y Letter dated 04/12/10 from John Hanger, Secretary , PADEP to Shawn M. Garvin, RA and a copy of the plan,“ State Implementation Plan Revision: Attai nment Demonstration and Base Year Inventory Pennsylvania portion of the Philadelphia
Wilmington, PA
NJ - DE Fine Particulate Nonattainment Area , ” dated April 2010 .**Regulatory**

**Citation Requirement**  **Completeness References**  **Y, N, or N/A Location in SIP**  2.1(c) Has the State provided evidence it has the necessary legal authority under State law to adopt and implement the plan? Y 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 dut y to implement the provisions of the CAA in the Commonwealth. 35 P.S. §§4004(1).**Regulatory**

**Citation Requirement**  **Completeness References**  **Y, N, or N/A Location in SIP**  2.1(d) Has the official State regulation/document been

signed/stamped/dated b y the appropriate State official indicating that it is fully

enforceable b y the State? Y A cop y of the plan, “State Implementation Plan Revision: Attainment Demonstration and Base Year Inventory Pennsylvania portion of the Philadelphia
Wilmington, PA
NJ - DE Fine Particulate Nonattainment Area , ” dated Nov ember 2010
. 2.1(d) The submittal should include a cop y of the actual regulation, or document submitted for approval

and incorporation by

reference into the plan, including indication of the changes made (such as, redline/strikethrough) to the existing ap proved plan, where applicable. The submittal shall be a copy of the official State regulation /document signed, stamped and 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. 2.1(d) If the State submits an electronic cop y, it must be an exact duplicate of the hard cop y with

changes indicated . S igned documents need to be in portable document format, ru les need to be in text format . F iles need to be submitted in manageable size s (e.g., a file for each section or chapter, depending on size, and separate files for each distinct document) unless otherwise agreed to b y the State and Regional Office.**Regulatory**

**Citation Requirement**  **Completeness References**  **Y, N, or N/A Location in SIP**  2.1(e ) Has the State provided evidence it followed all of the

procedural requirements of the State’s laws and constitution in the adoption/issuance of the plan? Y Letter dated 04/12/10 from John Hanger, Secretary, PADEP to Shawn M. Garvin, RA; copy of the Notic e “Proposed Revision to the State Implementation Plan for the Philadelphia
Wilmington, PA
-NJ DE Penn sylvania Fine Particulate Nonattainment Area; Public Hearing” published in the Saturday, February 6, 2010 edition of th e Pennsylvania Bulletin [40 Pa. B. 756 ]; and a copy of the affidavit of publication and of the public notice
.**Regulatory**

**Citation Requirement**  **Completeness References**  **Y, N, or N/A Location in SIP**  2.1(f) Has the State provided evidence that public notice was given

of the proposed change consistent with procedures approved by EPA, including the date of publication of such noti ce? Y Pennsylvania published a public notice of the proposed revision to the SIP and a notice of a public hearing on the proposed changes in the Pennsylvania Bulletin on February 6, 2010 [40 Pa. B . 756 ]. A copy of the affidavit of publication and the publ ic notice was published in the February 5, 2010 , edition of the Bucks Count y Courier Times
. 2.1(g) Has the State provided a certification that public hearings(s)

were held in accordance with the information provided in the public notice and the State’s laws and constitution, if applicable, and consistent with the public hearing requirements in 40 CFR 51.102? Y T he SI P submittal letter dated 04/12/10 from John Hanger, Secretary , PADEP states that the public hearing was held on March 11, 2010, in Norristown , P A .**Regulatory**

**Citation Requirement**  **Completeness References**  **Y, N, or N/A Location in SIP**  2.1(h) Has the State provided a compilation of public comments

and the State’s response thereto? Y T he SI P submittal letter dated 04/12/10 from John Hanger, Secretary , PADEP states that a comment and response document was not prepared because no c omments were received. 

### Technical Requirements from **Part 51, Subpart Z**  **§ 51.1002 Submittal of State**  **im plementation plan.**  51.1002 (a) Was the SIP submitted within 3 y ears from the date of

designation? N Submitted April 12, 2010 . - PM Impl. Rule, 20587 ,

20599 51.1002 (b) The State must submit a plan consistent with the requirements of section 110(a)(2) of the Act

unless the State alread y has fulfilled this obligation for the purposes of i mplementing the PM 2.5 NAAQS. - 110(a) Guidance 51.1002 (c) Does the SIP identify and evaluate sources of PM 2.5 direct emissions and PM 2.5 attainment plan precursors? 1 Y Section I
. Introduction and Overview
. - EI Guidance (Section 3.2)

- PM Impl. Rule, 20651
- 20655. 51.1002 (c)(1) Does the SIP address SO 2 as a PM 2.5 attainment p lan

precursor and evaluate sources of SO 2 emissions in the State for control measures? Y Sectio n I . Introduction and Overview. - PM Impl. Rule, 20594

1 After January 1, 2011, for purposes of establishing emissions limits under 51.1009 and 51.1010, States must establish such li mits ta king into consideration the condensable fraction of direct PM 2.5 emissions. Prior to this date, States are not prohibited from establishing source emission limits that include the condensable fraction of direct PM 2.5 .**Regulatory**

**Citation Requirement**  **Completeness References**  **Y, N, or N/A Location in SIP**  51.1002 (c)(2) If the State and EPA have not provide d an appropriate

technical demonstration for a specifi c area showing that NO x emissions from sources in the State do not significantly contribute to PM 2.5 concentrations in the nonattainment area , d oes the SIP address NO x as a PM 2.5 precursor and evaluate sources of NO x emissions in the State for control meas ures ? Y Section I
. Introduction and Overview
. - PM Impl. Rule, 20594 ,

20597

51.1002 (c)(3)(i)
- (ii) If the State or EPA has provided a demonstration showing

that the State’s VOC emissions significantly contribute to PM 2.5 concentrations in the NAA, has the State addressed VOC as a PM 2.5 attainment plan precursor and evaluated sources of VOC emissions in the State for control measures? N/A Section I
. Introduction and Overview
. - PM Impl. Rule, 20592 ,

20597
51.1002 (c)(4)(i)
- (ii) If the State or EPA has provid ed a demonstration showing

that the State’s NH 3 emissions significantl y contribute to PM 2.5 concentrations in the NAA, has the State addressed NH 3 as a PM 2.5 attainment plan precursor and evaluated sources of NH 3 emissions in the State for control measures ? N/A Sectio n I . Introduction and Overview. - PM Impl. Rule, 20591 ,

20597
51.1002 (c)(5) I f the administrative record related to development of the

State’s SIP shows that the presumption in th e PM 2.5 Implementation Rule for a P M 2.5 precursor with respect to a particular NAA is not technically justified , has the State submitted a demonstration to reverse that presumption? N/A - PM Impl. Rule, 20597
**§ 51.1004 Attainment dates.**  51.1004 (a) Is the proposed attainment date as expeditious as practicable ,

but no lat er than 5 y ears from the date the area was designated nonattainment, or no later than 10 ye ars from designation in the event the state is proposing an extension ? Y Section I
. Introduction and Overview
. - PM Impl. Rule, 20600 ,

**20601** , 206 02, 20612
- 20614. S ee also RACT/RACM requirements and preamble language
.**Regulatory**

**Citation Requirement**  **Completeness References**  **Y, N, or N/A Location in SIP**  51.1004 (a) Preamble interpretation of 51.1004(a) indicates that the attainment date that is “ as expeditious as

practicable ” should reflect the projected impact of : (1) existing programs (e.g., partial implementation of the CAIR rule, final Acid Rain Program, motor vehicle tier II standards and heav y - dut y diesel engine standards, NO x SIP call, State legislation and rules ) , (2) expeditious implementation of all RACM and RACT local control measures , and (3 ) potential reasonable measures to reduce intrastate transport emissions from sources within the S tate’s jurisdiction. - PM Impl. Rule, 20600, 20601 **,** 20602, 20612 , 2013, 20614. See also RACT/RACM requirements and preamble language. See also 51.2007(b). 51. 1004 (b) Has the State submitted an attainment demonstration

justifying its proposed attainment date ? Y Section V. Attainment Demonstration and Weight of Evidence (WOE). - PM Impl. Rule, 20600

51.1004 (b) If the state is proposing an attainment date later th an 5 y ears from the area’s date of designation,

has the state provided a justification for the extension based on the severity of nonattainment and the availability

and feasibility

of pollution control measures? - PM Impl. Rule, 20600
- 20602, 20612
- 20614

- See also RACT/RACM requirements and preamble language. **§ 51.1007 Attainment demonstration and modeling**  **r equirements.**  51.1007 (a) T he State must submit an attainment demonstration f or an y area designated as nonattainment showing that the area will attain the annual and 24
- hour standards as expeditiously as practicable. - PM Impl. Rule, 20601 51.1007 (a) T he attainment demonstration must meet the requirements of :

- § 51.112 (Demonstration of control strategy adequacy), and

- Appendix W to part 51 (Guideline on Air Quali ty Models). - PM Impl. Rule, 20608

- EIGuidance

- Modeling Guidance 51.1007 (a) Does the attainment demonstration include all of the items

below as part of the basis for the State’s projected attainment date?

- EIdata

- modeling results

- emission reduction anal yse s Y Appendices A through H. - PM Impl. Rule, 20647,

20605**Regulatory**

**Citation Requirement**  **Completeness References**  **Y, N, or N/A Location in SIP**  51.1007 (a) T he attainment date justified by the demonstration must be consistent with the requirements of § 51.1004(a)
. - PM Impl. Rule, 20609

- Modeling Guidance (Section 3.5) 51.1007 (a) T he modeled str ategies in the demonstration must be consistent with the requirements of:

- §51.1009 for RFP , and

- § 51.1010 for RACT and RACM
. - PM Impl. Rule, 20610
- 20632

- PM Impl. Rule, 20633
- 20640 51.1007 (a) The attainment demonstration and supporting air quality modeling should be consistent with

EPA’s PM 2.5 modeling guidance. - Modeling Guidance 51.1007 (b) For all control measures needed for attainment, the S IP must provide for implementation as

exped i tiously

as practicable, but no later than the beginning of the ye ar prio r to the attainment date. - PM Impl. Rule, 20610 **§ 51.1008 Emission inventory requirements for the**  **PM 2.5**  **NAAQS.** 51.1008 (a)(1) Has the State submitted statewide EIs (under subpart A) for

direct PM 2.5 emissions and emissions of PM 2.5 precursors ? Y Appendices B2 and C2. - EIGuidance 51.1008 (a)(2) Has the State s ubmitted any additional EI information needed to support an attainment demonstration and RFP plan ensuring expeditious attainment of the annual and 24
- hour PM 2.5 standards? Y

– attainment demo N/A
- RF P Appendices B2

and C2. - EIGuidance (Section

3.3.2) 51.1008 (b) Has the State s ubmitted a baseline EI for the attainment

demonstration under **§** 51.1007, and for meeting RFP requirements under **§** 51.1009 ? Y

– attainment demo N/A
- RFP Appendices B2

and C2. - PM Impl. Rule, 20647

- EIGuidance **§51.1009 Reasonable further progress (RFP) requirements. 2**  51.1009 (c) If the SIP demonstrate s the area needs an attainment date of

more than five ye ars from the date of designation, has the State submitted a separate RFP plan? N/A See footnote 2 - PM Impl. Rule, 20633

2 A separate RFP plan is not requir ed for an area i f the State submits to EPA an attainment demonstration and State implementation plan demonstrat ing th e area will attain the PM NAAQS within five years of the date of designation.**Regulatory**

**Citation Requirement**  **Completeness References**  **Y, N, or N/A Location in SIP**  51.1009 (c)(1) If the SIP justif ies an attainment date greater than five and less than nine y ears from the date of designation , does the RFP plan include 2009 emissions milestones for direct PM 2.5 and PM 2.5 attainment plan precursors demonstrating RFP for the 2009 emissions y ear? N/A See footnote 2 - PM Impl. Rule, 20634

51.1009 (c)(2) If the SIP justifies an attainment date of nine or ten y ears

from the date of designation , does the RFP plan include 2009 and 2012 em issions milestones for direct PM 2.5 and PM 2.5 attainment plan precursors demonstrating RFP for the 2009 and 2012 emissions y ears? N/A See footnote 2 - PM Impl. Rule, 20634

- PM Impl. Rule, 20640
51.1009 (d) T he RFP plan must demonstrate generall y linear progre ss in reducing emissions between the

base year and the attainment y ear. - PM Impl. Rule, 20634 51.1009 (e) For a multi
- State nonattainment area, is RFP demonstrated

on the basis of common multi
- State inventories ? N/A See footnote 2 - PM Impl. Rule, 20640 51. 1009 (e) For a multi
- State nonattainment area, have the States

submitted a coordinated RFP plan? N/A See footnote 2 - PM Impl. Rule, 20640 51.1009 (e) For a multi
- State nonattainment area, has each State ensured

its sources comply

with enforceable emission l evels and other requirements that in combination with the reductions planned in other state(s) will provide for attainment as expeditiously

as practicable and demonstrate RFP? N/A See footnote 2 - PM Impl. Rule, 20640

51.1009 (f) In the benchmark RFP plan, h as the State :

- identif ied direct PM 2.5 emissions and PM 2.5 attainment plan precursors regulated under the PM 2.5 attainment plan, and

- specif ied target emission reduction levels to be achieved during the milestone y ears? N/A See footnote 2 - PM Impl. Rule, 2063 9

51.1009 (f) In developing the benchmark RFP plan, has the State

developed EI information for the geographic area included in the plan? N/A See footnote 2 - PM Impl. Rule, 20636
- 20639**Regulatory**

**Citation Requirement**  **Completeness References**  **Y, N, or N/A Location in SIP**  51.1009 (f)(1) For direct PM 2.5 emissions and each addressed PM 2.5 precur sor, the full implementation

reduction must be calculated b y subtracting the full implementation inventory from the baseline ye ar inventory
. - PM Impl. Rule, 20639 51.1009 (f)(2) T he “milestone date fraction” must be calculated as the ratio of the number of ye ars from the

baseline year to the milestone inventory ye ar divided by the number of y ears from the baseline ye ar to the full implementation y ear. - PM Impl. Rule, 20639 51.1009 (f)(3) For direct PM 2.5 emissions and each addressed PM 2.5 precursor, the bench mark emission

reduction must be calculated b y multiplying the full implementation reduction by the milestone date fraction
. - PM Impl. Rule, 20639 51.1009 (f)(4) T he benchmark emission level in the milestone y ear must be calculated for direct PM 2.5

emissions and each PM 2.5 attainment plan precursor by subtracting the benchmark emission reduction from the baseline y ear emission level. - PM Impl. Rule, 20639 51.1009 (f)(5) In comparing EI s between baseline and future ye ars for direct PM 2.5 emissions and each PM 2. 5

precursor, the EI s must be derived from the same geographic are a. - PM Impl. Rule, 20636 51.1009 (f)(5) T he plan must include emissions estimates for all ty pes of emitting sources and activities in the geographic area from which the EI s for direct PM 2.5 e missions and each PM 2.5 precursor addressed in the plan are derived. - PM Impl. Rule, 20636 51.1009 (f)(6) Has the State include d in its RFP submittal an inventory of on - road mobile source emissions in the PM 2.5 nonattainment area f or purposes of establishin g motor vehicle emissions budgets for transportation conformity (as required in 40 CFR part 93) ? (Note section on “ Applicability Requirements from Part 93” below.) N/A See footnote 2 - PM Impl. Rule, 20645

51.1009 (g) The RFP plan must demonstrate emissions for the milestone y ear are either:

(1) At levels that are roughl y equivalent to the benchmark emission levels for direct PM 2.5 emissions and each precursor to be addressed in the plan; or (2) At levels included in an alternative scenario projected to resu lt in a generall y equivalent improvement in air quality b y the milestone ye ar as would be achieved under the benchmark RFP plan. - PM Impl. Rule, 20639**Regulatory**

**Citation Requirement**  **Completeness References**  **Y, N, or N/A Location in SIP**  51.1009 (h) If applicable, the equivalence of an alternative scenario to the corresponding benchmark plan

must be determined b y comparing the expected air quality changes of the two scenarios at the design value monitor location. This comparison must use the information developed for the attainment plan to assess the relationship between emissions reductions of the direct PM 2.5 emissions and each PM 2.5 attainment plan precursor addressed in the attainment strategy and the ambient air quality

improvement for the associated ambient species. - PM Impl. Rule, 20639

**§ 51.1010 Requirements for RACT**  **and RACM .**  51.1010 ( a) The State must submit a SIP revision demonstrating it has adopted all RACM (including RACT)

necessary to achieve attainment as expeditiously as practicable and to meet any RFP requirements. - PM Impl. Rule, 20610
- 20632 51.1010 (a) Does the SIP revision co ntain :

- the list of the potential measures considered b y the State , and

- information and anal ys is to support the State’s judgment that it has a dopted all RACM, including RACT? Y Section IV. B. - PM Impl. Rule, 20610
- 20632
51.1010 (b) In determining whether a particular emission reduction

measure or set of measures must be adopted as RACM under section 172(c)(1) of the CAA, has the State consider ed the cumulative impact of implementing the available measures ? Y Section IV . C. - PM Impl. Rule, 20610
- 20632 (20614) 51 .1010 (b) Potent ial measures that are reasonabl y available considering technical and economic feasibility

must be adopted as RACM if, considered collectively , they would advance the attainment date by one ye ar or more. - PM Impl. Rule, 20611, 20614, 20617 **§ 5**  **1.1012 Requirement for contingency measures.** 51.1012 (a) Consistent with section 172(c)(9) of the Act, has the State

submitted specific contingency measures to be undertaken if the area fails to make RFP, or fails to attain the PM 2.5 NAAQS b y its attainment date ? Y Section VI . B. - PM Impl. Rule, 20643
51.1012 (a) Does the submittal indicate the above contingency measures must take effect without significant further action by the State or EPA? Y Section VI . A. - PM Impl. Rule, 20643 

### Applicability Requirements fr **om Part 93, Subpart A (Transportation Conformity)** **Regulatory**

**Citation Requirement**  **Completeness References**  **Y, N, or N/A Location in SIP**  **§93.102 Applicability.**  93.102(b)(1) Does the SIP include one of the following:

- a MV emissions budget established for direct PM 2.5 , or

- a demonstration that regional on
- road mobile source emissions are an insignificant contributor to the PM 2.5 air quality problem as provided under the transportation conformity

rule (40 CFR 93.109(k))? Y Section III.E. - PM Impl. Rule, 20645
- 20646
93.102(b)(2)(v) Does the SIP include one of the following:

- a MV emissions bu dget established for direct SO 2 , or

- a demonstration that regional on
- road mobile source emissions are an insignificant contributor to the SO 2 air quality problem as provided under the transportation conformity

rule (40 CFR 93.109(k))? Y Section III.E. - PM Impl. Rule, 20645
- 20646
93.102(b)(2)(iv) Does the SIP include one of the following:

- a MV emissions budget established for NOx, or

- a demonstration that regional on
- road mobile source emissions are an insignificant contributor to the PM 2.5 air quality probl em as provided under the transportation conformity

rule (40 CFR 93.109(k)), or

- a demonstration that NOx is not an attainment plan precursor as provided in 40 CFR 51.1002(c)(5)? Y Section III.E. - PM Impl. Rule, 20645
- 20646

93.102(b)(2)(v) Does the SIP incl ude one of the following:

- a MV emissions budget established for VOC, or

- a demonstration that regional on
- road mobile source emissions are an insignificant contributor to the PM 2.5 air quality problem as provided under the transportation conformity

rule (40 CFR 93.109(k)), or

- a demonstration that VOC is not an attainment plan precursor as provided in 40 CFR 51.1002(c)(5)? Y Section III.E. - PM Impl. Rule, 20645
- 20646**Regulatory**

**Citation Requirement**  **Completeness References**  **Y, N, or N/A Location in SIP**  93.102(b)(2)(v) Does the SIP include one of the following:

- a MV emissions budget establishe d for ammonia, or

- a demonstration that regional on
- road mobile source emissions are an insignificant contributor to the PM 2.5 air quality problem as provided under the transportation conformity

rule (40 CFR 93.109(k)), or

- a demonstration that ammonia is no t an attainment plan precursor as provided in 40 CFR 51.1002(c)(5)? Y Section III.E. - PM Impl. Rule, 20645
- 20646

93.102(b)(3) If re
- entrained road dust emissions are considered a

significant contributor to the area’s PM 2.5 air quality problem, does the SIP include these emissions in the direct PM 2.5 MV emissions budget? Y

– accounted for in direct PM budget. Section III.E. - PM Impl. Rule, 20645

- Transp. Conf. Rule, 40033
- 40034 93.102(b)(3) For an y re - entrained road dust that is included in the MV emissions budget, the November 2006

version of AP
- 42 or an EPA
- approved local methodology should be used for estimating such emissions. - Road Dust Guidance 93.122(f) If transportation construction
- related fugitive dust emissions

are considered a significant contri butor to the area’s PM 2.5 air quality problem, does the SI P include these emissions in the direct PM 2.5 MV emissions budget? N/A - Transp. Conf. Rule, 40035
- 40036 

### Technical Requirements from Part 51, Subpart K **(Source Surveillance) §51.211**  **Emission report s and recordkeeping**  **.** 51.211(a) & (b) Does the SIP provide procedures for maintaining records of

and periodicall y reporting to the State the ty pes and amounts of emissions as well as information needed to determine compliance? Y Appendix B.1.
- SIP Prepar ation Rule , 40673 **§51.212 Testing, inspection, enforcement, and complaints**  **.** 51.212(a) Does the SIP provide for periodic testing and for periodic

inspection of stationary

sources ? 3 Y In each control measure in Section IV . A. - CE Rule, 8328

3 EPA recommends testing at least once per permit term and in spections at least once per year.**Regulatory**

**Citation Requirement**  **Completeness References**  **Y, N, or N/A Location in SIP**  51.212(c) Doe s the SIP contain enforceable test methods for each

specified emission limit? Y In each control measure in Section IV .A . - CE Rule, 8328 **§51.214 Continuous emission monitoring.**  51.214(a) Does the SIP contain provisions requiring stationary sources subje ct to emissions standards of the plan to install, calibrate, maintain, and operate equipment for continuously monitoring and recording emissions ? Y The measures have CEMs where they are required b y EPA. - SIP Preparation Rule ,

40673 51.214(b) Does the SIP identify the ty pes of sources and source categories that must install the continuous monitoring equipment and what pollutants must be monitored (presumabl y PM 2.5 )? 4 Y EGUs under CAIR are required
. - SIP Preparation Rule ,

40673 51.214(c) Does the SIP , a s a minimum, require the t ypes of sources set

forth in Appendix P of part 51 to meet the requirements therein for continuous emission monitoring and recording? Y The measures have CEMs where they are required b y EPA. - SIP Preparation Rule ,

40673 51.214(d ), (e) & (f) Does the SIP contain provisions requiring stationary sources subject to emissions standards of the plan to:

- maintain a file of all pertinent information for at least two ye ars,

- submit to the State information relating to emissions and operatio n of the emission monitors, and

- have installed all necessary equipment and to have begun monitoring and recording within 18 months of either a pproval of the SIP or p romulgation by EPA of monitoring requirements for a specific source (as a minimum, applies to sources set forth in Appendix P of part 51)? Y In each measure that relied on the SIP. - SIP Preparation Rule ,

40673

4 EPA recommends identifying sources and source categories other than fossil fuel fired steam generators, fluidized bed catalyst cr acking unit catalyst regenerators, sulfuric acid plants, and nitric acid plants.