  SEQ CHAPTER \h \r 1 SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST

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

   SIP Submitted by:  Commonwealth of Pennsylvania

     Date Submitted:  September 25, 2006

            Subject:  Reasonably Available Control Technology (RACT) for
Philadelphia County

Completeness Review Base File Number:  PA229

				S/S

Completed by:             Christopher Cripps, 3AP21

     Date Completed:   March 26, 2007

Administrative Materials

                                                                        
        SEQ CHAPTER \h \r 1 ACCEPTABLE

  SEQ CHAPTER \h \r 1 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 Kathleen A. McGinty, Secretary of the Pennsylvania Department of
Environmental protection dated September 25, 2006.	 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.  Not a regulatory change.  The submittal
is a certification that the Pennsylvania RACT regulations meet RACT for
the 8-hour ozone NAAQS.  The certification is effective September 2006.	
X

3. Evidence that the State has the necessary legal authority under State
law to adopt and implement the plan.	3.  State has legal authority to
adopt this RACT certification under Section 5 of the Air Pollution
Control Act.  Philadelphia AMS has the authority to adopt and develop
the certification under Philadelphia Air management Code §3-301 of the
Philadelphia Code and 25 Pennsylvania Code, Subpart C, Article III.	 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.  The submittal is a certification that the
Pennsylvania RACT regulations meet RACT for the 8-hour ozone NAAQS.  The
certification is effective September 2006.	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.  Letter from Kathleen A. McGinty,
Secretary of the Pennsylvania Department of Environmental protection
dated September 25, 2006.  Copy 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.  Copy of notice printed in the July 31st
and August 1st and 2nd  2006 editions of The Philadelphia Daily News..  
 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. Letter from Kathleen A. McGinty,
Secretary of the Pennsylvania Department of Environmental protection
dated September 25, 2006.  	 X

8. Compilation of public comments and the State's response thereto.	8.  
 No comments were received.	 





  SEQ CHAPTER \h \r 1 Technical Materials

  SEQ CHAPTER \h \r 1 EPA REQUIREMENT	STATE SUBMITTAL 	(X)

  SEQ CHAPTER \h \r 1 1. Identification of all regulated pollutants
affected by the plan.	1.  Section 2 of the certification identifies that
VOC and NOx RACT rules are the subject of the certification.	  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 certification
covers all the sources in the Philadelphia County portion of the
Philadelphia-Wilmington-Atlantic City 8-hour ozone nonattainment area..	
 

  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.  Revision certifies existing
RACT rules in the SIP.  No change in emissions is expected.	 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.  
Not required (N/R) for RACT.  RACT is setting emission limits based upon
technological & economic feasibility considerations.	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. 
Not required for RACT.  RACT is setting emission limits based upon
technological & economic feasibility considerations.	X

6. Evidence, where necessary, that emission limitations are based on
continuous emission reduction technology.	6.  Air Management Regulations
(AMRs) ) codified at 40 CFR 52.2020(3): AMR V §II, AMR III., AMR V.
§IV.; AMR V. §V., AMR V. §VI.; AMR V. § VII., AMR V. §VIII.; AMR V.
§X., AMR V. § XI.; AMR V. §XII., AMR V. §XIII.; Pennsylvania
regulations codified at 40 CFR 52.2020(c)(1): 25 Pa Code §§129.51,
129.52, 129.55, 129.56, 129.57, 129.58, 129.59, 129.60, 129.61, 129.62,
129.63, 129.64, 129.65, 129.67, 129.68, 129.69, 129.71, 129.72, 129.73,
129.75, 129.101-107; and the source specific RACT determinations
codified at 40 CFR 52.2020(d)(1) (Philadelphia County Facilities).	X

7. Evidence that the plan contains emission limitations, work practice
standards and recordkeeping/reporting requirements, where necessary, to
ensure emission levels.	7.  Revision certifies existing RACT rules in
the SIP.  See, for example, Air Management Regulations (AMRs) codified
at 40 CFR 52.2020(3) such as AMR V §II, AMR III., AMR V. §IV.; AMR V.
§V., AMR V. §VI.; AMR V. § VII., AMR V. §VIII.; AMR V. §X., AMR V.
§ XI.; AMR V. §XII., AMR V. §XIII.; Pennsylvania regulations codified
at 40 CFR 52.2020(c)(1): 25 Pa Code §§129.51, 129.52, 129.55, 129.56,
129.57, 129.58, 129.59, 129.60, 129.61, 129.62, 129.63, 129.64, 129.65,
129.67, 129.68, 129.69, 129.71, 129.72, 129.73, 129.75, 129.101-107; and
the source specific RACT determinations codified at 40 CFR 52.2020(d)(1)
(Philadelphia County Facilities).	X

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

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).	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 a section 107 request.	X



