UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION Ill 

1650 Arch Street 

Philadelphia, Pennsylvania 19103-2029 

The Honorable Michael L. Krancer, Secretary 

Pennsylvania Department of Environmental Protection 

Rachel Carson State Office Building 

P.O. Box 2063 

Harrisburg, Pennsylvania 17105-2063 

Dear Secretary Krancer: 

JUL 2 6 2'012 

On June 26, 2012, the Environmental Protection Agency received a revision to the 

Pennsylvania State Implementation Plan (SIP) submitted by your department on June 25,2012, 

pertaining to Allegheny County Health Department's (ACHD) incorporation of Pennsylvania's 

New Source Review regulations by reference and revisions to related definitions. 

EPA has determined that the submittal is administratively and technically complete, and 

is reviewing it to prepare a Notice of Proposed Rulemaking (NPR) action. 

If members of your staff have any questions, they may direct them to Paul Wentworth, 

Office of Permits and Air Toxics, at (215) 814-2183. He is the principal contact for this 

rulemaking. 

cc: Ms. Joyce E. Epps, P A DEP 

Mr. James Thompson, ACHD 

Sincerely, 

~-~ki;· Diana Esher, irector 

Air Protection Division 

Customer Service Hotline: 1-800-438-2474 

SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST 

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

SIP Submitted by: Pennsylvania Department of Environmental Protection 

Date Submitted: 6/25/2012 

Subject: Amendments to Allegheny County Health Department (ACHD) Rules and Regulations, Article XXI, Air Pollution 

Control regarding regulations incorporating New Source Review Program 

Completeness Review 

Completed by: Paul Wentworth 

Date Completed: 7/17/2012 

Administrative Materials 

ACCEPTABLE 

I :E:P A UQ-tJIREMENT I STATE SUBMITTAL I (X) I 

1. A formal letter of submittal from the Governor or his 1. A Letter dated June 25, 2012 on behalf of the X 

klesignee, requesting EPA approval of the plan or revision Commonwealth ofPennsylvania from Michael L. Krancer, 

thereof. Secretary, PADEP, to Shawn M. Garvin, Regional 

Administrator, EPA Region III is included in this submission. 

2. Evidence that the State has adopted the plan in the State code 2. Certification of Approval and Adoption signed by Henry X 

pr body of regulations; or issued the permit, order, or consent Miller III, Esquire, and notarized 4/27/2012 and included with 

agreement in final form. That evidence shall include the date this SIP submission contains this evidence. The revisions have 

of adoption or final issuance as well as the effective date of the no sunset date. 

tplan, 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. 

3. Evidence that the State has the necessary legal authority 3. The Plan revision was submitted through PA DEP. PA has X 

~nder State law to adopt and implement the plan. authority to revise and implement SIP with EPA oversight and 

approval. 
EPAREQUlREMENT I STATESUBMITTAL I(X) ~- A copy of actual regulation, or document submitted for 4. Document entitled: "Allegheny Health Department Changes 

approval and incorporation by reference into the plan, including to New Source Review Regulations and Major Source 

indication of the changes made to the existing approved plan, Definitions" containing revised Sections under Article XXI: 

where applicable. The submittal shall be a copy ofthe official 2101.02 Definitions; 2102.04 Installation Permits; 2102.06 IX 

State regulation/document signed, stamped, dated by the Major Sources Locating in or Impacting a Nonattainment Area; 

appropriate State official indicating that it is fully en£)fceable 2102.08 Emission Offset Registration. Transmittal letter from 

!by the State. The effective date of the regulation/document James Thompson, Manager, Allegheny Health Department, 

shall, whenever possible, be indicated in the document itself. dated April 30, 2012 states that the revision is effective April 3, 

2012. 

5. Evidence that the State followed all of the procedural 

!requirements ofthe State's laws and constitution in conducting 

and completing the adoption/issuance of the plan. 

5. Certification of Approval and Adoption signed by Henry 

Miller III, Esquire, and notarized 4/27/2012 and included with 

this SIP submission states that this SIP revision was duly and 

properly enacted as prescribed by Local Health Administration 

Law and the Second Class Charter Law. 

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. Certification Signed by Alaina Conner, Pollution Prevention I X 

and Outreach Coordinator, Allegheny Health Department, 

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. 

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

hereto. 

dated 4/30/2012 and included in this submission states that a 

public hearing was held on 9112/2012 on the proposed 

amendments and that the opportunity for written comments was 

given in accordance with the requirements of 40 CFR 51.102 

and that notice of such hearing was given by publication in a 

newspaper of general circulation on 8/8/2011 and that such 

proceedings were in full compliance with all applicable State 

and Federal laws, regulations, and other !"equirements. 

7. As described in the above paragraph 

8. Compilation of public comments and state responses is 

enclosed with submission of the SIP revision 

Technical Materials 

X 

X 

1. Identification of all regulated pollutants affected by the plan. !1. The regulations contained in the submission satisfy this by I X 
EPA VltRE~NT 

2. Identification of the locations of affected sources including 

the EPA attainrnent/nonattainrnent designation of the locations 

and the status of the attainment plan for the affected area(s). 

3. Quantification ofthe changes in plan allowable emissions 13. N/A 

,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 I 

sources through calculations of the differences between certain 

jbaseline levels and allowable emissions anticipated as a result 

~f the revision. 

STATE SUBMITTAL (X) 

X 

The State's demonstration that the national ambient air 

uality 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 will be equivalent to the revised federal IX 

NSR permitting program which is intended to assist in attaining 

the National Ambient Air Quality Standards (NAAQS) for all 

applicable nonattainrnent pollutants in Allegheny County. The 

regulations will support the current approved NSR program in 

Pennsylvania. The revision to the definition of "Major" 

source will enable the state to administer their Title V program 

for greenhouse gasses. 

5. Modeling information required to support the proposed 15. N/A 

evision, including input data, output data, models used, 

ambient monitoring data used, meteorological data used, 

·ustification 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. 

6. Evidence, where necessary, that emission limitations are 16 N/ A 

[based on continuous emission reduction technology. 

7. Evidence that the plan contains emission limitations, work 17. N/A 

tpractice standards and recordkeeping/reporting requirements, 

!where necessary, to ensure emission levels. 
EJ;J A REQUIREMENT STATE SUBMITTAL (X) 

8. Compliance/enforcement strategies, including how 8.N/A 

compliance will be determined in practice. 

9. Special economic and technological justifications required by 9.N/A 

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

explain why.) 

1 0. A Section 107 request must be accompanied by a 10. N/A 

maintenance plan demonstrating maintenance to the relevant 

NAAQS for at least 10 years after redesignation. .. )