SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST

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

SIP Submitted by: Commonwealth of Virginia

Date Submitted: September 17, 2015

Subject: Amendments to the Definition of Volatile Organic Compounds 

Completeness Review 

Completed by: Irene Shandruk

Date Completed: October 6, 2015

Administrative Materials Acceptable

EPA REQUIREMENT STATE SUBMITTAL 

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 September 17, 2015 from David K. Paylor, 

Director, Virginia Department of Environmental Quality to 

Diana Esher, Director, Air Protection Division, 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. Revision was adopted by the Commonwealth of Virginia on 

September 5, 2014 under the authority of section 10.1-1308 of 

the Code of Virginia, and in accordance with the requirements 

of 40 CFR Parts 50 and 51. 

3. Evidence that the State has the necessary legal authority 

under State law to adopt and implement the plan.

3. Revision adopted pursuant to section 10.1-1308 of the Code 

of Virginia.

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 

regulation/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 

4. A copy of the regulation was published in the Virginia 

Register on June 15, 2015 with effective date July 30, 2015. 
EPA REQUIREMENT STATE SUBMITTAL 

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.

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. Submittal of September 17, 2015 provided documentation 

that all State procedures were followed in adoption of the 

regulation.

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. Notice of public hearing was published in the Virginia 

Register on August 10, 2015, and the public comment period 

was held from August 10 through September 9, 2015. 

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. In the notice for 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. No public comments were received.

Technical Support

EPA REQUIREMENT STATE SUBMITTAL (X)

1. Identification of all regulated pollutants affected by the plan. 1. N/A – This revision is an administrative action.

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. N/A – This revision is an administrative action and will not 

affect any sources in Virginia.

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 

3. N/A – This revision is an administrative action and does not 

include any changes to allowable or actual emissions.
EPA REQUIREMENT STATE SUBMITTAL (X)

sources through calculations of the differences between certain 

baseline levels and allowable emissions anticipated as a result 

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. N/A – This revision is an administrative action and will not 

affect the state’s ability to protect the national ambient air 

quality standards, prevention of significant deterioration 

increments, reasonable further progress demonstration, and 

visibility.

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. N/A – This revision is an administrative action and no 

modeling information is needed.

6. Evidence, where necessary, that emission limitations are 

based on continuous emission reduction technology.

6. N/A – This revision is an administrative action adding two 

chemical substances to the list of substances not considered to 

be VOCs contained in 9VAC5-10-20 of the Virginia SIP 

because this list has been updated by the EPA.

7. Evidence that the plan contains emission limitations, work 

practice standards and recordkeeping/reporting requirements, 

where necessary, to ensure emission levels.

7. N/A – This revision is an administrative action and does not 

affect any emission limits, work practice standards, or 

recordkeeping requirements which ensure emission levels.

8. Compliance/enforcement strategies, including how 

compliance will be determined in practice.

8. N/A – This revision is an administrative action and does not 

affect compliance or enforcement strategies.

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