SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST

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

SIP Submitted by: West Virginia Department of Environmental Protection

Date Submitted: August 7, 2013

Subject: West Virginia’s Redesignation Request and Maintenance Plan for the Martinsburg-Hagerstown, WV-MD 1997 

Annual Fine Particulate Matter (PM2.5) Nonattainment Area

Completeness Review 

Completed by: Rose Quinto

Date Completed: September 18, 2013

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. Submittal letter dated August 5, 2013 from West Virginia 

Department of Environmental Protection Secretary Randy C. 

Huffman, to Shawn M. Garvin, Regional Administrator, EPA 

Region 3.

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. Not applicable. Not a regulatory change - the submittal is a 

request for redesignation, a maintenance plan, and 2007 base 

year inventory approval. 

X

3. Evidence that the State has the necessary legal authority

under State law to adopt and implement the plan.

3. The West Virginia’s plan states that it has the necessary legal 

authority and necessary resources to enforce its rules or permit 

provisions on which the plan is based. 

X
2

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. Not applicable, see 2 above. 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. Not applicable. 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. A notice of public hearing and a public comment period was 

published in the West Virginia Register, the Charleston Gazette 

and the Martinsburg Journal on June 14, 2013. 

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. A transcript of the public hearing showed the public hearing 

was held in accordance with the public notice. 

X

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

thereto.

8. Appendix G of the State submittal includes a copy of the 

comments received and the response to comments.

X
3

Technical Materials

EPA REQUIREMENT STATE SUBMITTAL 

1. Identification of all regulated pollutants affected by the 

plan.

1. Section 3 of the Redesignation Request and Maintenance 

Plan show that nitrogen oxide (NOx), sulfur dioxide (SO2), 

PM2.5, volatile organic compound (VOC) and ammonia (NH3)

are the pollutants affected by the plan. 

 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. Martinsburg-Hagerstown, WV-MD PM2.5 nonattainment 

area comprising Berkeley County in West Virginia.

 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. Detailed information on the point, area, nonroad and mobile 

source emissions estimates used in the request for 

redesignation, the PM2.5 maintenance plan, and the 2007 base 

year emissions inventory for the Martinsburg-Hagerstown Area 

is provided in the submittal. 

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. West Virginia has developed a base year (2007) and 

projected (2015 and 2025) emissions inventories showing 

continued attainment of the PM2.5 national ambient air quality

standard (NAAQS) during the plan period. 

 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. X
4

6. Evidence, where necessary, that emission limitations are 

based on continuous emission reduction technology.

6. Not applicable. X

7. Evidence that the plan contains emission limitations, work 

practice standards and recordkeeping/reporting requirements, 

where necessary, to ensure emission levels.

7. Based on permanent and enforceable measures, West 

Virginia has projected emissions inventories for interim year 

2015 and out year 2025 to demonstrate maintenance 

throughout the entire 10-year period. 

 X

8. Compliance/enforcement strategies, including how 

compliance will be determined in practice.

8. Identified contingency measures will be implemented if the 

Area violates or exceeds the PM2.5 standard. These measures 

are intended to bring the area back to attainment of the

standard.

 X

9. Special economic and technological justifications required 

by any applicable EPA policies. (If a policy is not appropriate, 

explain why.)

9. Not applicable. 

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. A Maintenance Plan was submitted to EPA Region III on

August 5, 2013. This plan demonstrates maintenance for 2015

through 2025. 

 X