SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST

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

 SIP Submitted by: Commonwealth of Pennsylvania

 Date Submitted: January 12, 2011

 Subject: Amendments to Title 25 of the Pennsylvania Code, Chapters 121, 129, and 130.

Completeness Review 

Completed by: Gregory Becoat /s/

 Date Completed: July 13, 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, Secretary of the Pennsylvania 

Department of Environmental Protection received January 25, 

2011.

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, Chapters 121, 129, and 130, published 

in the Pennsylvania Bulletin on December 25, 2010 (40 Pa.B.

7340).

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.

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 on December 25, 2010 (40 Pa.B. 7340), 

amending Title 25 of the Pennsylvania Code, Chapters 121, 

129, and 130. As stated in the preamble to the final-form 
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.

rulemaking these amendments went into effect on December 

25, 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, Secretary of the Pennsylvania 

Department of Environmental protection received January 25, 

2011. A copy of notice printed in the December 25, 2010 

edition of the Pennsylvania Bulletin (40 Pa.B. 7340) 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 March 28, 2009 edition of The 

Tribune-Democrat, in the March 27, 2009 edition of the 

Tribune-Review, in the March 28, 2009 edition of the 

Williamsport Sun-Gazette, in the March 28, 2009 edition of 

Delaware County Daily Times, in the March 28, 2009 edition 

of the Altoona Mirror, in the March 28, 2009 edition of The 

Times Herald, in the March 28, 2009 edition of The PatriotNews, in the March 28, 2009 edition of the Erie Times News, 

in the March 28, 2009 edition of Bucks County Courier Times, 

in the March 28, 2009 edition of The Time Leader, in the 

March 28, 2009 edition of The Pittsburgh Post Gazette, in the 

March 28, 2009 edition of The Philadelphia Inquirer, in the 

March 28, 2009 edition of The Morning Call.

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 March 28, 2009 edition of 

The Tribune-Democrat, in the March 27, 2009 edition of the 

Tribune-Review, in the March 28, 2009 edition of the 

Williamsport Sun-Gazette, in the March 28, 2009 edition of 

Delaware County Daily Times, in the March 28, 2009 edition 

of the Altoona Mirror, in the March 28, 2009 edition of The 

Times Herald, in the March 28, 2009 edition of The PatriotNews, in the March 28, 2009 edition of the Erie Times News, 

in the March 28, 2009 edition of Bucks County Courier Times, 
EPA REQUIREMENT STATE SUBMITTAL (X)

in the March 28, 2009 edition of The Time Leader, in the 

March 28, 2009 edition of The Pittsburgh Post Gazette, in the 

March 28, 2009 edition of The Philadelphia Inquirer, in the 

March 28, 2009 edition of The Morning Call.

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, Secretary of the Pennsylvania 

Department of Environmental protection received on January 

25, 2011. 

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

thereto.

8. The document titled “PENNSYLVANIA

Adhesives, Sealants, Primers and Solvents, 25 Pa. Code 

Chapters 121, 129 and 39 Pa.B. 1636 (April 4, 2009)

Environmental Quality Board Regulation #7-428 (Independent 

Regulatory Review Commission #2755), Comment/Response 

Document.”

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 December 25, 2010

edition of the Pennsylvania Bulletin. 

 

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.

 

 

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 21.8 tons per summer day beginning with the 2012 

ozone monitoring season. Refer to section G. “Benefits, Costs 

and Compliance” in the preamble to the notice published in the 

December 25, 2010 edition of the Pennsylvania Bulletin. 

4. The State's demonstration that the national ambient air 

quality standards, prevention of significant deterioration 

4. This revision will reduce ozone precursor emission 

throughout the Commonwealth and therefore will reduce ozone 
increments, reasonable further progress demonstration, and 

visibility, as applicable, are protected if the plan is approved 

and implemented. 

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.

6. Evidence, where necessary, that emission limitations are 

based on continuous emission reduction technology.

6. Not applicable.

7. Evidence that the plan contains emission limitations, work 

practice standards and recordkeeping/reporting requirements, 

where necessary, to ensure emission levels.

7. The SIP already contains sections which contain the needed 

recordkeeping/reporting requirements. 

8. Compliance/enforcement strategies, including how 

compliance will be determined in practice.

8. Not applicable.

9. Special economic and technological justifications required by

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

explain why.)

9. Not applicable.

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.