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

SIP Submitted by: 

     Date Submitted: September 30, 2019

     Subject:  Attainment Demonstration for the Allegheny County, PA Nonattainment Area for the 2012 Fine Particulate Matter National Ambient Air Quality Standards



Completeness Review 

     Completed by:  Marilyn Powers

     Date Completed:  October 28, 2019


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.   Yes, letter signed September 30, 3019 from Patrick McDonnell, Secretary (PADEP) to Cosmo Servidio, Regional Administrator (EPA Region III).
                                       

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.   Yes, the plan was adopted on September 11, 2019 by the Allegheny County Board of Health.
                                       

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

3.  Yes, ACHD is authorized under PA State Law to adopt and implement the Allegheny County portion of the PA SIP.  The ACHD has an air pollution control program that has been approved by PADEP in accordance with Section 12 of the Commonwealth's Air Pollution Control Act, 35 P.S. § 4012.
                                       

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.    A copy of the attainment plan, including the modeling demonstration, RACT/RACM, RFP, contingency measures, and base year emissions inventory, was submitted.  The submittal includes a certification that the SIP revision was adopted by the ACHD Board of Health on September 11, 2019, was duly and properly enacted, and is fully and legally enforceable by ACHD.  The certification was signed by the ACHD Assistant Solicitor and notorized.
                                       

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 Certification of Hearing in section 13.4 states that ACHD followed applicable State laws, regulations and other requirements.
                                       

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.  Section 13.3 of the submittal provides a May 9, 2019 notice of publication in the Pittsburgh Post-Gazette, which shows a 30 day comment period and the date for the public hearing.  
                                       

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 Certification of Hearing in section 13.4 of the submittal certifies that a public hearing was held on June 11, 2019 in accordance with the public notice and in compliance with applicable State law and other requirements.
                                       

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

8.  Appendix M of the submittal is a compilation of the public comments received and ACHD's responses.
                                       

Technical Support

	EPA REQUIREMENT

	STATE SUBMITTAL 
                                      (X)

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

1.  Yes, the attainment plan identifies the 2012 PM2.5 NAAQS, including its precursors.  
                                       

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, the affected sources are located within the Allegheny County PM2.5 nonattainment area.  
                                       

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.  Yes, ACHD projected allowable emissions of PM2.5 and its precursors anticipated as a result of the revision for comparison to base case levels. 
                                       

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.  Yes, the attainment plan includes a modeling demonstration to show that the Area will attain 2012 PM2.5 NAAQS.   
                                       
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.  Yes, appendices in the submittal include protocols for the models used, ambient monitoring data used, meteorological data used, emissions inventory used, model performance evaluations, and alternative modeling demonstration for buoyant fugitives. ACHD submitted a hard drive with input and output data files.
                                       

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

6.  Table 6.2 of the submittal shows the control technology for sources in the nonattainment area, including continuous emission reduction technology for:  SO2 and NOx emissions at Clairton are controlled by FGD and combustion controls, respectively; GenOn Cheswick SO2 and NOx emissions are controlled by FGD and SCR respectively, and Bay Valley is equipped with LNB and FGR.
                                       

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

7.  The permits for affected sources contain operational restrictions and emission limitations, work practice standards including inspection, repair, and maintenance requirements.  Part 75 reporting and recordkeeping requirements apply for boilers with CEMs.  SIP-approved ACHD regulation 2103.12j and 2103.12k set forth recordkeeping and reporting requirements in permits, and SIP-approved ACHD regulation 2108.01 establishes additional reporting requirements for sources with controls.  Additional recordkeeping/reporting requirements are included in Title V permits for the affected sources. 
                                       

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

8.  Yes, compliance/enforcement will be determined via enforcement of permit requirements.  Continuous emissions monitoring (CEMs) are required for boilers at Clairton, GenOn, and Bay Valley.
                                       

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

9.   N/A, no special economic or technological justification required.
                                       
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, not a Section 107 request.
                                       

