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 Becoat /s/

Date Completed: March 30, 2016

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 from David K. Paylor, Director, Virginia Department

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 adopt 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.

 X
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.

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 implementation 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 information 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, 2015.

X

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

thereto.

8. No public comments were received. X
Technical Materials

EPA REQUIREMENT STATE SUBMITTAL (X)

1. Identification of all regulated pollutants affected by the plan. 1. Enclosure 1 of the 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/nonattainment 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 

standards, 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 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. Not applicable. No modeling demonstration was required 

to support the required revision. 

X
6. 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 applicable. 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