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, Chapter 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 

October 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 

Pennsylvania Bulletin, Volume 40, Number 37, Pages 5137 

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. The final-form rulemaking is authorized under 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 

Commonwealth.

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 

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 129, specifically: (1) amending

X
EPA 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 12.952; 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, 2010 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 Environmental 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 copy 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 13, 

2010 edition of The Times-Leader (Wilkes-Barre), in the 

January 15, 2010 edition of the Pittsburgh-Post Gazette, in the 

January 15, 2010 edition of The Morning Call (Allentown), in 

the January 14, 2010 edition of the Williamsport Sun-Gazette, 

in the January 16, 2010 edition of The Patriot-News

(Harrisburg), in the January 15, 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 15, 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 13, 2010 edition 

of The Times-Leader (Wilkes-Barre), in the January 15, 2010

edition of the Pittsburgh-Post Gazette, in the January 15, 2010

edition of The Morning Call (Allentown), in the January 14, 

2010 edition of the Williamsport Sun-Gazette, in the January 

16, 2010 edition of The Patriot-News (Harrisburg), in the 

X
EPA REQUIREMENT STATE SUBMITTAL (X)

January 15, 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 15, 2010 edition of the Scranton Times.

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 letter from John Hanger, Acting Secretary of the 

Pennsylvania Department of Environmental protection dated 

October 1, 2010 and 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 Chapter 129, 40 Pa.B. 420 (January 16, 

2010) Environmental Quality Board Regulation #7-449

(Independent Regulatory Review Commission #2813), 

Comment/Response Document.”

X

Technical materials

1. Identification of all regulated pollutants affected by the plan. 1. Volatile organic compounds (VOCs) as identified in the 

preamble to the notice published in the September 11, 2010 

edition of the Pennsylvania Bulletin. 

 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. The amendments will affect VOC emissions throughout the 

Commonwealth including nonattainment areas and 

maintenance areas.

 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. These amendments are anticipated to result in reduction of 

VOCs by approximately 5.5 tons per year from Large 

Appliances coating operations 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, 2010 edition of 

the Pennsylvania Bulletin. 

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. 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 offsite 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 standards and recordkeeping/reporting requirements, 

where necessary, to ensure emission levels.

7. The emission standards are found in the new sections 

129.52a(c) and Tables I and II. The required work practice 

standards are found in sections 129.52a(f) and (h). The 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] This revision references Chapter 139 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 

X
controls are used. 

9. Special economic and technological justifications required 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 after redesignation.

10. Not applicable. This is not a section 107 request. N/A