SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST

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

SIP Submitted by: Pennsylvania Department of Environmental Protection

Date Submitted: March 25, 2014

Subject: Pennsylvania Regional Haze State Implementation Plan Revision: BART Limits for the Cheswick Power Plant, Allegheny 

County

Completeness Review /s/

Completed by: Irene Shandruk

Date Completed: April 23, 2014

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 March 25, 2014 from E. Christopher Abruzzo, 

Secretary, Pennsylvania Department of Environmental 

Protection to Shawn M. Garvin, Regional Administrator.

X

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

body of regulations; or issued the permit, order, 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. The State has submitted evidence that the regulations and 

permits were issued and approved in accordance with the 

Allegheny County Health Department (ACHD) via issuance of 

the ACHD November 7, 2012 Review Memo.

X

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

State law to adopt and implement the plan.

3. Allegheny County Health Department (ACHD) has legal 

authority under Local Health Administration Law, Act 315 of 

August 24, 1951, P.L. 1304. ACHD has an air pollution control 

program that has been approved by PADEP in accordance with 

Section 12 of the Air Pollution Control Act.

X
EPA REQUIREMENT STATE SUBMITTAL (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 by the State. The 

effective date of the regulation/document shall, whenever possible, 

be indicated in the document itself.

4. A copy of the ACHD November 7, 2012 Review Memo was 

submitted. X

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. Cover letter transmitting the SIP revision dated March 25, 

2014. Copies and certification of public hearing notices. 

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 and public comment period was 

published in the Pennsylvania Bulletin on December 21, 2013 as 

well as in numerous newspapers.

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. Public hearings were scheduled for January 21, 2014, but 

were cancelled due to the lack of public interest.

X

8. Compilation of public comments and the State's response thereto. 8. One public comment was received and a response was 

provided. Comments from the Federal Land Managers were also 

received and the responses were provided.

X
Technical Materials

EPA REQUIREMENT STATE SUBMITTAL (X)

1. Identification of all regulated pollutants affected by the plan. 1. The submittal identifies PM10, SO2, and NOx. 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. Allegheny County in the Commonwealth of Pennsylvania. 

 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. The plan established requirements to limit PM10 emissions 

from the Cheswick Power Plant and additionally corrected 

emission limit for SO2 and NOx by removing these limits and 

relying upon the CAIR requirements. 

 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. The SIP revision consists of a demonstration that a

correction to the Pennsylvania Regional Haze SIP will have 

minimal visibility impact, and thereby will protect air quality.

 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. Appropriate modeling demonstration was included in 

support of the required revision.

 X

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

continuous emission reduction technology.

6. The plan corrected requirements to limit PM10 from the 

Cheswick plant.

 X
EPA REQUIREMENT STATE SUBMITTAL (X)

7. Evidence that the plan contains emission limitations, work practice 

standards and recordkeeping/reporting requirements, where

necessary, to ensure emission levels.

7. The plan established requirements to limit PM10 emissions 

from the Cheswick plant, which was incorporated in the 

Installation Permit and the Title V Operating Permit. 

 X

8. Compliance/enforcement strategies, including how compliance 

will be determined in practice.

8. The plan established requirements to limit PM10 emissions 

from the Cheswick plant, which was incorporated in the 

Installation Permit and the Title V Operating Permit. 

 X

9. Special economic and technological justifications required by any 

applicable EPA policies. (If a policy is not appropriate, explain why.)

9. No special justifications are required. 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. Not applicable because this is not a section 107 request. X