SIP Submitted by: 

Date Submitted: 

Subject: 

Completeness Review 

SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST 

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

Virginia Department of Environmental Quality 

March 18, 2014 

Revision of the Virginia State Implementation Plan to Remove Stage II Gasoline Vapor Recovery 

Controls from the Virginia Jurisdictions Located in the Ozone Transport Region 

Completed by: Asrah Khadr 

Date Completed: 511114 

Administrative Materials ACCEPTABLE 

EPA REQUIREMENT STATE SUBMITTAL (X) 

1. A formal letter of submittal from the Governor or his 1. Letter dated March 18, 2014 from David K. Paylor, X 

designee, requesting EPA approval of the plan or revision Director, Virginia Department of Environmental Quality to 

hereof. Diana Esher, Director, Air Protection Division, EPA Region 

III. 

2. Evidence that the State has adopted the plan in the State code 2. N/A- Not a regulatory change. The submittal updates the 

jor body of regulations; or issued the permit, order, consent attainment and maintenance plans for the Virginia Jurisdictions N/A 

!agreement in final form. That evidence shall include the date located in the ozone transport region (OTR) to address changes of adoption or final issuance as well as the effective date of the to emission reductions in those plans associated with the 

plan, if different from the adoption/issuance date. upcoming removal of the Stage II gasoline vapor recovery 

program. The plan is a demonstration that removal of the 

program will not interfere with the area's ability to maintain the 

Ozone National Ambient Air Quality Standard (NAAQS). 

3. Evidence that the State has the necessary legal authority 3. The SIP revision was issued pursuant to§ 10.1-1185 of the X 

under State law to adopt and implement the plan. Code of Virginia. 
EPA REQUIREMENT STATE SUBMITTAL (X) 

~-A copy of actual regulation, or document submitted for 4. This SIP revision contains no regulation or materials for 

approval and incorporation by reference into the plan, including incorporation by reference. A copy of the revision to the X 

indication of the changes made to the existing approved plan, attainment and maintenance plan, including a demonstration that 

where applicable. The submittal shall be a copy of the official the Stage II program does not interfere with attainment or 

State regulation/document signed, stamped, dated by the maintenance of the ozone NAAQS has been included. 

appropriate State official indicating that it is fully enforceable 

lby the State. The effective date of the regulation/document Virginia will need to conduct a rulemaking process to 

shall, whenever possible, be indicated in the document itself. remove the Stage II regulation from the VA Code, and then to 

submit a separate SIP revision to EPA to amend the SIP to 

reflect that rule change. 

5. Evidence that the State followed all of the procedural 5. Virginia attests in its submittal letter to EPA that the X 

requirements of the State's laws and constitution in conducting Commonwealth approved and submitted the plan to EPA under 

and completing the adoption/issuance of the plan. authority of§ 10.1-1185 ofthe Code ofVirginia. 

6. Evidence that public notice was given of the proposed 6. Copy of public notice published on February 10, 2014, in X 

change consistent with procedures approved by EPA, including the Virginia Register of Regulations announcing the SIP 

the date of publication of such notice. revision, the public comment period, and the public hearing. 

7. Certification that public hearings were held in accordance 7. Certification that public comment period and public notice X 

!With the information provided in the public notice and the were conducted in accordance with 40 CFR 51.102(a), 40 CR 

State's laws and constitution, if applicable. 51.1 02( d)(l ), and 40 CFR 51.1 02( d)(2). 

8. Compilation of public comments and the State's response 8. N/A. No public comments were received. N/A 

thereto. 
Technical Materials 

EPA REQUIREMENT STATE SUBMITTAL I(X) 

1. Identification of all regulated pollutants affected by the plan. 1. Volatile organic compounds (VOCs) are affected by the 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). 

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. 

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 

~d implemented. 

5. Modeling information required to support the proposed 

:revision, including input data, output data, models used, 

ambient monitoring data used, meteorological data used, 

"ustification 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. 

6. Evidence, where necessary, that emission limitations are 

!based on continuous emission reduction technology. 

plan. 

2. The Virginia jurisdictions in the OTR. The jurisdictions 

with the exception of Stafford County have been designated as 

marginal for the 2008 Ozone NAAQS. 

3. The SIP revision quantifies the emissions impacts from 

removal of the Stage II gasoline vapor recovery program. The 

SIP revision also includes an analysis that removal of the 

program will not interfere with the area's ability to 

maintain/attain the ozone NAAQS under 11 0(1) ofthe Clean 

Air Act. 

X 

X 

4. The SIP contains a demonstration that the future removal of X 

the Stage II program does not interfere with attainment or 

maintenance of the Ozone NAAQS. The SIP does not address 

reasonable further progress, visibility, or prevention of 

significant deterioration, etc. 

5. The plan contains the required MOVES modeling to 

calculate the impact ofthe removal of Stage II, per EPA's 

Stage II Removal Guidance. The SIP also contains an 

emission inventory comparison of Stage II and total emissions, 

as well as a transportation conformity budget analysis for NOx 

and VOC emissions, etc. 

Virginia also included additional "weight of evidence" analysis 

to support its demonstration, including an airshed modeling 

sensitivity study ofthe Southeastern U.S. conducted by 

Georgia Tech. 

6. Not applicable. 

X 

N/A 
EPA REQum.EMENT STATE SUBMITTAL (X) 

7. Evidence that the plan contains emission limitations, work 7. Not applicable. 

tpractice standards and recordkeeping/reporting requirements, N/A 

jwhere necessary, to ensure emission levels. 

8. Compliance/enforcement strategies, including how 8. Not applicable. N/A 

compliance will be determined in practice. 

9. Special economic and technological justifications required 9. Virginia references EPA's "Guidance on Removing Stage II X 

by any applicable EPA policies. (If a policy is not appropriate, Gasoline Vapor Control Programs from State Implementation 

explain why.) Plans and Assessing Comparable Measures," dated August 

2012. That guidance establishes methods for analyzing the 

impact of removal/replacement of Stage II vapor recovery 

programs from the state SIP. 

10. A Section 107 request must be accompanied by a 10. Not applicable because this is not a section 107 request. NIA 

maintenance plan demonstrating maintenance to the relevant 

NAAQS for at least 10 years after redesignation.