	SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST
	(in accordance with 40 CFR Part 51 - App. V)

SIP Submitted by:
Commonwealth of Pennsylvania
     Date Submitted: 
Date Submitted by PADEP - April 11, 2019  -  ARD Received on April 16, 2019
     Subject:
Case-by-Case RACT Determinations for 1997 & 2008 8-Hour Ozone NAAQS for 10 Facilities


Completeness Review 

     Completed by:
Emily Bertram
     Date Completed:
10/2/19

Administrative Materials												ACCEPTABLE

	EPA REQUIREMENT

	STATE SUBMITTAL 
                                      (X)

1. A formal signed, stamped, and dated letter of submittal from the Governor or his designee, requesting EPA approval of the plan or revision thereof.  If electing to submit a paper submission with a copy in electronic version, the submittal letter must verify that the electronic copy provided is an exact duplicate of the paper submission.

1. Letter was sent to EPA on April 11, 2019 from PADEP Secretary, Patrick McDonnell.  EPA received the letter in ARD on April 16, 2019. 
                                       

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.  PADEP provided a table showing the names of the facilities that case-by-case RACT determinations were completed for, along with the permit # and permit issuance/effective date. 
                                       

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

3.  Yes.
                                       

4. A copy of actual regulation, or document submitted for approval and incorporation by reference into the plan, including indication of the changes made (such as redline/strikethrough) to the existing approved plan, where applicable.  The submission shall include 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 any regulation/document contained in the submission shall, whenever possible, be indicated in the regulation/document itself; otherwise the State should include a letter signed, stamped, and dated by the appropriate State official indicating the effective date.  If the regulation/document provided by the State for approval and incorporation by reference into the plan is a copy of an existing publication, the State submission should, whenever possible, include a copy of the publication cover page and table of contents.

4.  Yes, PADEP provided EPA with a redacted permit for EPA to incorporate by reference the necessary permit provisions into the state implementation plan (SIP).    
                                       

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. Yes. 
                                       

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. Yes, for each facility.
                                       

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.  Yes, for each facility.
                                       

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

8.  Yes, for each facility.
                                       

Technical Support

	EPA REQUIREMENT

	STATE SUBMITTAL 
                                      (X)

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

1. Yes, RACT applies to VOC and NOx.  
                                       

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. Yes, each submission outlines the location of the source.  This SIP revision is being submitted to fulfill the Commonwealth's obligation for the 1997 and 2008 8-Hour Ozone NAAQS.    
                                       

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. As applicable, based on individual case-by-case RACT determinations.     
                                       

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. N/A   
                                       
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. N/A  
                                       

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. Yes.  
                                       

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

8. Yes.  
                                       

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

9. Yes, case-by-case RACT is determined based on a technological and economic feasibility analysis.   
                                       
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   
                                       


