	SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST

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

   SIP Submitted by: 	Pennsylvania Department of Environmental
Protection		

     Date Submitted:   	April 11, 2007	

            Subject:   	Conversion of the Philadelphia County CO
Maintenance Plan to a Limited Maintenance Plan 		 

Completeness Review 

Completed by: 	Catherine L. Magliocchetti	

     Date Completed: 	July 20, 2007

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 19, 2007, received on April 11, 2007, to Regional
Administrator Welsh from Secretary McGinty.	

   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.  Same as above, plus the SIP revision dated September 2005, (Revision
to the Pennsylvania State Implementation Plan for Maintaining the Carbon
Monoxide National Ambient Air Quality Standard for the Years 2007-2017
in Philadelphia County.(   	

 

  X



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

3.  PA DEP has the legal authority under the State Air Pollution Control
Act (Vol. 35 ( 4001).  	

  

  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 maintenance plan entitled (Revision to the Pennsylvania State
Implementation Plan for Maintaining the Carbon Monoxide National Ambient
Air Quality Standard for the Years 2007-2017 in Philadelphia County(,
dated September 2005, along with the submittal letter to EPA.	

  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. As discussed in the transmittal letter, and the letter from
Philadelphia AMS to PA DEP, the State and City followed all procedural
requirements as appropriate. 	

 

  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. . Public notice was given, evidence provided for in submittal,
including a copy of the published notice in The Philadelphia Daily News,
on October 17, 18 and 19, 2005.	

 

  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. Certification is found in Philadelphia AMS letter to PA DEP, signed
by Morris Fine, Director of AMS.	

 



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

8. No comments were received, see letter from Philadelphia AMS.	

  X



1. Identification of all regulated pollutants affected by the plan.	

1.  The SIP revision, dated September 2005, identifies that Carbon
Monoxide is the pollutant affected by this plan.	

  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. .  For maintenance purposes, the entire county of Philadelphia is
considered to be a maintenance area for CO.  While not described in the
SIP submittal, the portion of Philadelphia County that was described as
nonattainment was comprised of the Central Business District, or (CBD),
generally accepted to be the area bounded to the north by Vine Street,
to the south by South Street, to the west by the Schuykill River and to
the east by the Delaware River.  	

  

  

   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.  An attainment inventory is provided in the SIP submittal.	  

   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 Department will continue to monitor for attainment of the
standard and implement contingency measures if needed.       	

  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.  The SIP revision contains an attainment inventory, and an
explanation that under the LMPO, a project of emissions over the
maintenance period is not required.	

  X



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

6.  n/a	





7. Evidence that the plan contains emission limitations, work practice
standards and recordkeeping/reporting requirements, where necessary, to
ensure emission levels.	

7.  n/a	





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

8.  The Department will continue to monitor ambient air in the area . 
If a violation occurs contingency measures will be triggered ( see the
“Contingency Plan.”	

  X



9. Special economic and technological justifications required by any
applicable EPA policies. (If a policy is not appropriate, explain why.)	

9.  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.  n/a	





