SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST (in accordance with 40 CFR Part 51

- App. V)

SIP Submitted by: Commonwealth of Pennsylvania

Date Submitted: October 1, 2010 Subject: Amendments to Title 25 of the Pennsylvania Code, C hapter 129 , specifically: §§ 129.51 and 129.52 ; and,

Addition of a new Section 129.52a. Completeness Review Completed by: Christopher Cripps /s/ Date Completed: February 8, 2011

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 from John Hanger, Acting Secretary of the Pennsylvania Department of Environmental protection dated

O ctober 1, 2010

. 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. A copy of the final

- form rulemaking amending Title 25 of the Pennsylvania Code, Chapter 129, Sections 129.51 and 129.52 and adding Section 129.52A , published in the Pennsylvani a Bulletin , Volume 40

, Number 37, Page s 5 137 through 5139 (inclusive) , on September 11, 2010

. X

3. Evidence that the State has the necessary legal authority under State law to adopt and implement the plan. 3. Th e final

- form rulemaking is authorized u nder section 5 of the Air Pollution Control Act (APCA) (35 P. S. § 4005), which grants the Environmental Quality Board (Board) the authority to adopt rules and regulations for the prevention, control, reduction and abatement of air pollution in this

Common wealth. 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 o fficial 4. A copy of the final

- form rulemaking published in the Pennsylvania Bulletin

, Volume 40, Number 37, Pages 5137 through 5139 (inclusive), on September 11, 2010. , Title 25 of the Pennsylvania Code, Chapter 1 29 , specifically: (1) amending XEPA REQUIREMENT STATE SUBMITTAL (X)

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. §§ 129.51 and 12.95 2; and, (2) adding a new section 129.52a. As stated in the preamble to the final

- form rulemaking these

amendments went into effect on September 11, 20 10 the date of publication in the Pennsylvania Bulletin as final

- form rulemaking.

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. The letter from John Hanger, Acting Secretary of the Pennsylvania Department of Environment al protection dated October 1, 2010 Sections J. Regulatory Review , K. Findings

and L. Order in the final rulemaking preamble (40 Pa.B. 5136

- 5137, September 11, 2010). A c opy of notice printed in the January 16, 2010 edition of the Pennsylvania Bulletin ( 40 Pa.B.

420

- 425 ) which outlined compliance with regulatory review requirements including the dates of submissions and approval where necessary to the Independent Regulatory Review

Commission , the Board and the appropriate legislative

committees . Copy of the notice printed in the January 1 3
, 2010 edition of The Times

- Leader (Wilkes

- Barre), in the January 1 5 , 2010 edition of the Pittsburgh

- Post Gazette

, in the January 1 5, 2010 edition of The Morning Call (Allentown), in

the January 1 4 , 2010 edition of the Williamsport Sun

- Gazette

, in the January 16, 2010 edition of The Patriot

- News (Harrisburg), in the January 1 5 , 2010 edition of the Bucks County Courier Times

, in the January 16, 2010 edition of the Delaware County Daily Times , in the January 16, 2010 editi on of the Erie Times News , in the in the January 16, 2010 edition

of the Reading Times
, in the January 1 5 , 2010 edition of the

Scranton Times

. 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. Copy of the notice printed in the January 1 3 , 2010 edition

of The Times

- Leader (Wilkes

- Barre), in the January 1 5 , 2010

edition of the Pittsburgh

- Post Gazette , in the January 1 5, 2010

edition of The Mo rning Call (Allentown), in the January 1 4
, 2010 edition of the Williamsport Sun

- Gazette

, in the January 16, 2010 edition of The Patriot

- News (Harrisburg), in the XEPA REQUIREMENT STATE SUBMITTAL (X) January 1 5 , 2010 edition of the Bucks County Courier Times

, in the January 16, 2010 edition of the Delaware County Daily

Times , in the January 16, 2010 edition of the Erie Times

News , in the in the January 16, 2010 edition of the Reading

Times
, in the January 1 5 , 2010 edition of the Scranton Times

.
7. Certification that public hearings were h eld in accordance with the information provided in the public notice and the State's laws and constitution, if applicable. 7. The letter from John Hanger, Acting Secretary of the Pennsylvania Department of Environmental protection dated October 1, 2010 a nd enclosed comment and response

document

. X

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

thereto. 8. The document titled “ Control of VOC Emissions From Large Appliance and Metal Furniture Surface Coating

Processes

, 25 Pa. Code Chapt er 1 29

, 40 Pa.B. 420 ( January 16,

2010 ) Environmental Quality Board Regulation #7

- 4 49 (Independent Re gulatory Review Commission #2813 )

, Comment/Response Document .” X

Technical materials

1. Identification of all regulated pollutants affected by the pl an. 1. Volatile organic compounds (VOCs) as identified in the preamble to the notice published in the September 11, 2010

edition of the Pennsylvania Bulletin

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2. Identification of the locations of affected sources including

the EPA attainment/no nattainment designation of the locations and the status of the attainment plan for the affected area(s). 2. The amendments will affect VOC emissions throughout the Commonwealth including nonattainment areas and

main ten ance areas. X

3. Quantificat ion 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. These amendments are anticipated to result in reduction of VOCs by approximately 5.5 tons per year from Large Appliances coating opera tions and approximately 17.6 tons per year from metal furniture coating operations. Refer to section

G . “ Benefits, Costs and Compliance ” in the preamble to the

final rule notice published in the September 11, 20 10 edition of

the Pennsylvania Bulletin

. X4. 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 impl emented. 4. This revision will reduce ozone precursor emission throughout the Commonwealth and therefore will reduce ozone concentrations providing progress towards attainment of the ozone NAAQS in ozone nonattainment areas and assist

maintenance of the standard in ozone attainment and

maintenance areas.

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 of fsite data (where used), modes of models used, assumptions, and other information relevant to the determination of adequacy of the modeling analysis. 5. Not applicable. X

6. Evidence, where necessary, that emission limitations are

based on continuous emission reduction technology. 6 . The emission standards require compliance in mass VOC per volume of coating solids applied

. See tables I and II in new

section 129.52a. X

7. Evidence that the plan contains emission limitations, work practice standar ds and recordkeeping/reporting requirements, where necessary, to ensure emission levels. 7. The emission standards are found in the new section s 129.52a(c) and Tables I and II. The required work practice standards are found in sections 129.52a(f) and (h ) . Th e SIP already contains section 129.51(d) [a provision generally applicable to all standards in Chapter 129] which contain the needed recordkeeping/reporting requirements. New sections 129.52a(d) and (e) supplement the provisions of section 129.51

to specify the minimum content of the required records and the minimum record retention period. X

8. Compliance/enforcement strategies, including how compliance will be determined in practice. 8

. New section 129.52a(c) contains the emission limitations and the methods and averaging time provisions to be used to show compliance with the emission standards in Tables I and II

to section 129.52a. The SIP already contains section 129.51(d) [a provision generally applicable to all standards in Chapter 129] T his revision references Chapter 13 9 which is already in

the PA SIP and which contains test methods to be used to determine overall capture and control efficiency when add

- on Xcontrols are used.

9. Special economic and technological justifications re quired by any applicable EPA policies. (If a policy is not appropriate, explain why.) 9. Not applicable. 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 afte r redesignation. 10. Not applicable. This is not a section 107 request. N/A