### SIP Submitted by: Date Submitted: Subject:

Completeness Review SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST (in accordance with 40 CFR Part 51

- App. V) Virginia Department ofEnvironmental Quality March 18, 2014 Revision ofthe Virginia State Implementation Planto 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 EPAREQUIREMENT STATE SUBMITTAL (X) 

### 1. A formal letter ofsubmittal from the Governor orhis 1. Letter dated March 18, 2014 from David K. Paylor, X 

### designee, requesting EPA approval ofthe plan or revision Director, Virginia Department ofEnvironmental Quality to hereof. DianaEsher, 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 ofregulations; 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 inthe ozone transport region (OTR) to address changes ofadoption or final issuance as well as the effective date ofthe to emission reductions inthose plans associated with the plan, ifdifferent from the adoption/issuance date. upcoming removal ofthe Stage II gasoline vapor recovery program. The plan is a demonstration that removal ofthe 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 ofthe X 

### under State law to adopt and implement the plan. Code ofVirginia.EPA REQUIREMENT STATE SUBMITTAL (X)**~-A** copy ofactual regulation, or document submitted for 4. This SIP revision contains no regulation ormaterials for approval and incorporation by reference into the plan, includingincorporation by reference. A copy ofthe revision to the 

### X indication ofthe changes made to the existing approved plan, attainment and maintenance plan, including a demonstration that where applicable. The submittal shall be a copy ofthe official the Stage II program does not interfere with attainment or State regulation/document signed, stamped, dated bythe maintenance ofthe ozone NAAQS has been included. appropriate State official indicating that it is fully enforceable lby the State. The effective date ofthe 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 ofthe procedural 5. Virginia attests inits submittal letter to EPAthat the 

### X requirements ofthe State's laws and constitution in conducting Commonwealth approved and submitted the planto EPA under and completing the adoption/issuance ofthe plan. authority of§ 10.1-1185 ofthe Code ofVirginia. 6. Evidence that public notice was given ofthe proposed 6. Copy ofpublic notice published on February 10, 2014, in 

### X change consistent withprocedures approved by EPA, including the Virginia Register ofRegulations announcing the SIP the date ofpublication ofsuch notice. revision, the public comment period, and the public hearing. 7. Certificationthat public hearings were held in accordance 7. Certificationthatpublic commentperiod and public notice 

### X !Withthe information provided inthe public notice and the were conducted in accordance with 40 CFR 51.102(a), 40 CR State's laws and constitution, ifapplicable. 51.102(d)(l), and 40 CFR 51.102(d)(2). 8. Compilation ofpublic comments and the State's response 8. N/A. No public comments were received. N/A thereto.Technical Materials EPA REQUIREMENT 

### STATE SU B

MITTAL I(X) 1. Identification ofall regulated pollutants affected by the plan. 1. Volatile organic compounds (VOCs) are affected by the X 

## :2. Identification ofthe locations ofaffected sources including [the EPA attainment/nonattainment designation ofthe locations and the status ofthe attainmentplanfor the affected area(s). 3. Quantification ofthe changes inplan allowable emissions from the affected sources; estimates ofchanges in current !actual emissions from affected sources or, where appropriate, quantification ofchanges in actual emissions from affected sources through calculations ofthe differences between certain baseline levels and allowable emissions anticipated as a result ofthe revision. 4. The State's demonstration that the national ambient air quality standards, prevention ofsignificant deterioration increments, reasonable further progress demonstration, and !Visibility, as applicable, are protected ifthe plan is approved**~d** implemented. 

### 5. Modeling informationrequired to support the proposed :revision, including input data, output data, models used, ambient monitoring data used, meteorological data used, "ustification for use ofoffsite data (where used), modes of models used, assumptions, and other informationrelevant to the determination ofadequacy ofthe modeling analysis.

6. Evidence, where necessary, that emission limitations are !based on continuous emissionreduction technology. plan. 2. The Virginiajurisdictions inthe OTR. Thejurisdictions withthe exception ofStafford County have been designated as marginal for the 

### 2008 OzoneNAAQS. 3. The SIP revision quantifies the emissions impacts from removal ofthe Stage II gasoline vaporrecovery program. The SIP revision also includes an analysis that removal ofthe program will not interfere withthe 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 thatthe future removal of 

### X the Stage IIprogram does not interfere with attainment or maintenance ofthe Ozone NAAQS. The SIP does not address reasonable further progress, visibility, orprevention of significant deterioration, etc. 5. The plan contains the required MOVES modeling to calculate the impact ofthe removal ofStage II,perEPA's Stage II Removal Guidance. The SIP also contains an emission inventory comparison ofStage II and total emissions, as well as a transportation conformity budget analysis for NOx and VOC emissions, etc. Virginia also included additional "weight ofevidence" analysis to support its demonstration, including an airshed modeling sensitivity study ofthe SoutheasternU.S. conducted by Georgia Tech. 6. Not applicable. 

### X

N/AEPA 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 inpractice. 9. Special economic and technologicaljustifications required 9. Virginia references EPA's "Guidance on Removing Stage II 

### X by any applicable EPA policies. (Ifa 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 ofremoval/replacement ofStage 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.