SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST

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

SIP Submitted by: The Delaware Department of Natural Resources and Environmental Control (DE DNREC)

 Date Submitted: Letter dated 4/23/2015, received 5/1/2015

 Subject: Delaware 2011 Base Yeas State Implementation Plan (SIP) Emissions Inventory under the 2008 Ozone 

National Ambient Air Quality Standard (NAAQS)

Completeness Review 

 Completed by: Maria A. Pino

 Date Completed: June 30, 2015

Administrative Materials ACCEPTABLE

EPA REQUIREMENT STATE SUBMITTAL (X)

1. A formal signed, stamped, and dated letter of submittal from 

the Governor or his designee, requesting EPA approval of the 

plan or revision thereof. If electing to submit a paper 

submission with a copy in electronic version, the submittal 

letter must verify that the electronic copy provided is an exact 

duplicate of the paper submission.

1. Letter dated 4/23/2015, signed by DE DNREC Secretary 

Davis D. Small to Shawn M. Garvin, Regional Administrator, 

EPA Region III.

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. Secretary's Order No. 2014-A-0015, Re: Approving 

Revised Final Revisions to the Delaware 2011 Base Year 

State Implementation Plan (SIP) Emission Inventory for 

Volatile Organic Compounds (VOCs), Nitrogen Oxides 

(NOx), and Carbon Monoxide (CO) for Areas of Marginal 

Non-Attainment under the 2008 Ozone National Ambient 

Air Quality Standard (NAAQS).

Date of Issuance: 7/21/2014

Effective Date: 8/11/2014

3. Evidence that the State has the necessary legal authority 

under State law to adopt and implement the plan.

3. Delaware has legal authority to adopt, implement, and 

enforce rules, regulations, and plans under Title 7, Delaware 

Code, Chapter 60, as stated on page 4 of Secretary's Order No. 

2014-A-0015 and page 5 of the hearing report, the 

7/14/2014 memorandum to Secretary Small from Lisa A. 

Vest, DE DNREC Public Hearing Officer.
EPA REQUIREMENT STATE SUBMITTAL (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 (such as redline/strikethrough)

to the existing approved plan, where applicable. The 

submission shall include 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 any regulation/document contained in the 

submission shall, whenever possible, be indicated in the 

regulation/document itself; otherwise the State should include a 

letter signed, stamped, and dated by the appropriate State 

official indicating the effective date. If the 

regulation/document provided by the State for approval and 

incorporation by reference into the plan is a copy of an existing 

publication, the State submission should, whenever possible, 

include a copy of the publication cover page and table of 

contents.

4. 2011 Base Year State Implementation Plan (SIP) 

Emission Inventory for Volatile Organic Compounds 

(VOCs), Nitrogen Oxides (NOx), and Carbon Monoxide 

(CO) for Areas of Marginal Non-attainment under the 2008 

Ozone National Ambient Air Quality Standard, Final 

Report, dated 7/20/2014, (“7/20/2014 Final Report”)

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. Secretary's Order 2014-A-0015, dated November 

7/21/2014. 

Cover letter transmitting the SIP revision dated April 23,

2015. Copy of public hearing notices. Certification of public 

hearing notice.

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. The submittal included copies of the notices of public 

hearing

and public comment period published in the News Journal and 

the Delaware State News on 5/25/2014, and in the Delaware

Register of Regulations on 6/1/2014 (17 DE Reg 1197).

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. 4/20/2015 Certification stating that a public hearing was 

held on 6/26/2014, in accordance with the public notice. The 

4/23/2015 submittal letter certifies that a public hearing was 

held through the process established by the State of Delaware 

with proper 30 day notice prior to the hearing.
8. Compilation of public comments and the State’s response 

thereto.

8. N/A. A public comment was presented at the public hearing, 

and was addressed by DE DNREC at the hearing. The public 

had the opportunity to comment on the corrected data at the 

hearing and the following two weeks after the hearing prior to 

closing of the public record. As stated on page 4 of the 

7/14/2015 hearing officer’s report, “Again, Ms. Marconi was 

the only attendee of the public healing held on June 26,2014, 

and the correction identified by her in DSWA’s comments was 

corrected by the Department in its revised final proposed SIP 

revision. No other comments were received by the Department 

in this matter.”

Technical Support

EPA REQUIREMENT STATE SUBMITTAL (X)

1. Identification of all regulated pollutants affected by the plan. 1. VOCs, NOx, and CO emissions under the 2008 ozone 

NAAQS.

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. Marginal nonattainment areas under the 2008 ozone 

NAAQS, New Castle and Sussex Counties, and described in 

the Background and Requirements section of the 7/20/2014 

Final Report.

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. This is the 2011 Base Year Inventory, representing 

VOCs, NOx, and CO emissions in New Castle and Sussex 

Counties in calendar year 2011, as described in Section 1 of the 

7/20/2014 Final Report.

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. N/A. This is the 2011 Base Year Inventory, representing 

VOCs, NOx, and CO emissions in New Castle and Sussex 

Counties in calendar year 2011, as described in Section 1 of the 

7/20/2014 Final Report.
EPA REQUIREMENT STATE SUBMITTAL (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. Files with technical information & data supporting the 

emissions inventory are contained in CDs accompanying the 

submittal.

6. Evidence, where necessary, that emission limitations are 

based on continuous emission reduction technology.

6. N/A

7. Evidence that the plan contains emission limitations, work 

practice standards and recordkeeping/reporting requirements, 

where necessary, to ensure emission levels.

7. N/A

8. Compliance/enforcement strategies, including how 

compliance will be determined in practice.

8. N/A

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