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 w as 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 evidenc e 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 regul ation/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 sour ces; 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 emi ssions 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 source s 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 und er 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