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 . Sma ll t o 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 Pl an (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

Effectiv e Date: 8/11 /201 4

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 regula tion/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 Compo unds (VOCs), Nitrogen Oxides (NOx), and Carbon Monoxide (CO) for Areas of Marginal Non

- a ttainment 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 proce dural 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 2 3, 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 notice s 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 acco rdance 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 o f 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 hea ring 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

cor rected 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 nona ttainment 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

b aseline 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 th e 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