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

- App. V)

SIP Submitted by: Virginia Department of Environmental Quality

Date Submitted: October 26, 2015 Subject: Revision for Richmond Maintenance Area State Operating Permit for Implementing Reasonably Available Control

Technology (RACT) for Reynolds Consumer Products

Completeness Review: Completed by: Gregory Becoa t /s/ Date Completed: March 30, 2016

Administrative Materials

ACCEPTABLE

EPA REQUIREMENT STATE SUBMITTAL (X)

1. A formal le tter of submittal from the Governor or his designee, requesting EPA approval of the plan or revision thereof. 1. Letter from David K. Payl or, Director, Virginia Departme n t of Environmental Quality X

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. The Commonwealth has submitted evidence that the regulations were adopted and approved in final form on February 11, 2014, with an effective date of October 20, 2015. X

3. Evidence that the State has the necessary legal authority under State law to adop t and implement the plan. 3. State has the legal authority to adopt the state operating permit containing terms and conditions for the control of emissions for volatile organic compounds (VOCs) from the Reynolds Consumer Products under Section 10.1

- 1185 of the

Code of Virginia

. X

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 4. Virginia included a copy of the permit and the permit conditions in Attachment A to Enclosure 1, with an effective date of October 20, 2015. Xapplicable. 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 docum ent itself.

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. Letter from David K. Paylor, Director of the Virginia Department of Environmental Quality, dated October 26,

2015 . Copy of public hearing notice. Copy of notice printed in

the Style Weekly on September 16, 2015

. X

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. Cover letter transmitting the state implement ation plan (SIP) revision dated October 26, 2015. Copies and certification of public hearing notices. Copy of the notice printed in the Style Weekly on September 16, 2015. X

7. Certification that public hearings were held in accordance with

the infor mation provided in the public notice and the State's laws and constitution, if applicable. 7. Letter from David Paylor, Director, Virginia Department of Environmental Quality, as required by Section 2.2

- 4031 of the Code of Virginia, dated October 26, 201 5. X

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

thereto. 8. No public comments were received. XTechnical Materials

EPA REQUIREMENT STATE SUBMITTAL (X)

1. Identific ation of all regulated pollutants affected by the plan. 1. Enclosure 1 of t he submittal identifies that VOC is the regulated pollutant affected in this SIP revision. X

2. Identification of the locations of affected sources including the

EPA attainment/n onattainment designation of the locations and the status of the attainment plan for the affected area(s). 2. Richmond Maintenance Area in particular, Reynolds

Consumer Products. X

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. The plan is to convert a consent order for RACT into a state operating permit. Therefore it is not applicable. X

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

standard s, prevention of significant deterioration increments, reasonable further progress demonstration, and visibility, as applicable, are protected if the plan is approved and implemented. 4. Not applicable. X

5. Modeling information required to support th e 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 deter mination of adequacy of the modeling analysis. 5. Not applicable. No modeling demonstration was required to support the required revision. X6. Evidence, where necessary, that emission limitations are based

on continuous emission reduction technology

. 6 SIP revision includes RACT analysis for Reynolds

Consumer Products

. X

7. Evidence that the plan contains emission limitations, work practice standards and recordkeeping/reporting requirements, where necessary, to ensure emission levels. 7. Not appli cable. X

8. Compliance/enforcement strategies, including how compliance will be determined in practice. 8 Not applicable. X

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

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 . Not a section 107 request. X