SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST

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

SIP Submitted by: Virginia Department of Environmental Quality (VADEQ)

 Date Submitted: July 23, 2012

Subject: 2008 Ozone National Ambient Air Quality Standard (NAAQS) Infrastructure State Implementation Plan (SIP)

Completeness Review 

Completed by: Ruth Knapp

Date Completed: December 5, 2012

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. Yes, the July 23, 2012 letter was signed by David Paylor 

the Director of VADEQ as the approved designee for SIP 

submittals.

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. Yes, applicable sections of 110(a)(2) are adopted into the 

Virginia Air Pollution Control Law and/or Virginia’s SIP in 

40CFR Part 52

3. Evidence that the State has the necessary legal authority

under State law to adopt and implement the plan.

3. Yes, Virginia has the authority under Section 10.1-1185 of 

the Air pollution control law.

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 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.

4. Yes, all state regulations have been previously adopted and 

are just being certified as applicable in the July 23, 2012 

submittal.
EPA REQUIREMENT STATE SUBMITTAL (X)

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. Yes, the submittal certifying that Virginia meets all the 

applicable requirements of 110(a)(2) for Ozone was signed and 

submitted following the procedural requirements of the 

Commonwealth.

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. Yes, the notice of public comment period was published in 

the Virginia Register of Regulations on June 4, 2012. The 

notice announced that the comment period was from June 4, 

2012 through July 5, 2012.

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. Yes, in the notice of public comment the option was given 

for a hearing to be held, and no such request was received.

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

thereto.

8. Yes, public comments were received and the 

Commonwealth responded as required.

Technical Support

EPA REQUIREMENT STATE SUBMITTAL (X)

1. Identification of all regulated pollutants affected by the plan. 1. Yes, the plan regulates VOCs and NOx as precursors of 

Ozone.

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. Yes, all areas of Virginia, with the exception of Northern 

Virginia, were designated as attaining the standard. Northern 

Virginia, as part of the metropolitan Washington, DC area, was 

designated nonattainment, with a classification of marginal.

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 

3. No changes in the emissions will occur from the 

certification of the current regulations approved in Virginia’s 

SIP as a result of this revision.
EPA REQUIREMENT STATE SUBMITTAL (X)

of the revision.

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. Yes, Virginia’s major stationary sources are currently

subject to nonattainment NSR and PSD permitting programs.

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. The authority to do modeling is certified in this revision, but 

specific modeling is not required for this revision.

6. Evidence, where necessary, that emission limitations are 

based on continuous emission reduction technology.

6. Yes, Virginia has adopted control measures and emissions 

limitations that will continuously reduce emissions and are 

listed in 40 CFR 52.2420(e).

7. Evidence that the plan contains emission limitations, work 

practice standards and recordkeeping/reporting requirements, 

where necessary, to ensure emission levels.

7. Yes, Virginia maintains and reports ambient air quality data 

using approved EPA methods to EPA’s Air Quality System as 

prescribed in 40 CFR part 58. Virginia also requires stationary

sources to monitor and report emissions as prescribed in 

9VAC5 chapters 20, 40, and 50 under 40 CFR 52.2420

8. Compliance/enforcement strategies, including how 

compliance will be determined in practice.

8. Yes, Virginia’s enforcement emissions limitations and other 

control measures are those provisions listed in Virginia’s SIP in 

40 CFR 52.2420(c)

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