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: June 23, 2014

 Subject: 2010 Sulfur Dioxide National Ambient Air Quality Standard (NAAQS) Infrastructure State Implementation 

Plan (SIP)

Completeness Review 

 Completed by: Ellen Schmitt

 Date Completed: June 30, 2014

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 letter was signed by David Paylor the Director of 

VADEQ as the approved designee for SIP submittal on June 

18, 2014.

2. Evidence that the State has adopted the plan in the State code 

or body of regulations; or issued the permit, order, or 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 52.2420

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 being certified as applicable in the June 18, 2014 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 Sulfur Dioxide 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 July 1, 2013. The 

notice announced that the comment period was from July 1, 

2013 through August 1, 2013.

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, the notice for public comment announced that a public 

hearing would be held, including the timing and location.

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

thereto.

8. Yes, three comments were received from Sierra Club and 

one from EPA Region 3. All comments were summarized and 

Virginia provided responses to each comment.

Technical Support

EPA REQUIREMENT STATE SUBMITTAL (X)

1. Identification of all regulated pollutants affected by the plan. 1. Yes, the submittal consists of a demonstration that Virginia 

has met the applicable infrastructure requirements for the 2010 

sulfur dioxide 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. Yes, the entire Commonwealth was designated 

unclassifiable/attainment.

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. 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)

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 40, 50, 91, and 140 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