SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST

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

SIP Submitted by: Virginia Department of Environmental Quality

 Date Submitted: December 22, 2014

 Subject: Section 128 (State Boards) for all pollutants

Completeness Review 

 Completed by: Ellen Schmitt

 Date Completed: 1/12/15

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 December 18, 2014 from David K. Paylor,

Director, Virginia Department of Environmental Quality to 

Diana Esher, Director, Air Protection Division.

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 applicable portions of 9VAC5-170-20 and 170-210 

were adopted on September 5, 2014 and became effective on 

November 19, 2014.

3. Evidence that the State has the necessary legal authority 

under State law to adopt and implement the plan.

3. Yes, Virginia has the authority under Section 10.1-1308 of 

the Code of Virginia.

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. Yes, the revisions to the state regulation have been adopted 

and were included in the submittal.
EPA REQUIREMENT STATE SUBMITTAL (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. Yes, the cover letter transmitting the SIP revision is dated 

December 22, 2014; no public hearing was requested.

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, public notice was provided on November 17, 2014 in 

the Virginia Register of Regulations. The notice announced 

that a comment period would commence on November 17 and 

end December 17, 2014.

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, the option was given for a hearing to be held; no such 

request was received.

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

thereto.

8. Yes, no public comments were received.

Technical Support

EPA REQUIREMENT STATE SUBMITTAL (X)

1. Identification of all regulated pollutants affected by the plan. 1. N/A – These revisions are administrative actions.

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. N/A – These revisions are administrative actions and will 

not affect any sources in Virginia.

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. N/A – These revisions are administrative actions and do not 

include any changes to allowable or actual emissions.

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

quality standards, prevention of significant deterioration 

4. N/A – These revisions are administrative actions and will 

not affect the state’s ability to protect the national ambient air 
EPA REQUIREMENT STATE SUBMITTAL (X)

increments, reasonable further progress demonstration, and 

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

and implemented. 

quality standards, prevention of significant deterioration 

increments, reasonable further progress demonstration, and 

visibility.

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 – These revisions are administrative actions and no 

modeling information is needed.

6. Evidence, where necessary, that emission limitations are 

based on continuous emission reduction technology.

6. N/A – These revisions are administrative actions; adding 

section 9VAC5-170-210 and revising the related terms defined 

in 9VAC5-170-20 in order to meet the requirements of Clean 

Air Act section 128 and 110(a)(2)(E)(ii) for all pollutants.

7. Evidence that the plan contains emission limitations, work 

practice standards and recordkeeping/reporting requirements, 

where necessary, to ensure emission levels.

7. N/A – These revisions are administrative actions and do not 

affect any emission limits, work practice standards, or 

recordkeeping requirements which ensure emission levels.

8. Compliance/enforcement strategies, including how 

compliance will be determined in practice.

8. N/A – These revisions are administrative actions and do not 

affect compliance or enforcement strategies.

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