SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST

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

SIP Submitted by: Commonwealth of Virginia Department of Environmental Quality

Date Submitted: February 14, 2014

Subject: Submittal of the Commonwealth of Virginia’s Control of Emissions of Volatile Organic Compounds From Mondelēz 

Global LLC, Inc. (formerly Kraft Foods Global, Inc.) as a SIP Revision

Completeness Review 

Completed by: Irene Shandruk

Date Completed: February 21, 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. Letter dated February 14, 2014, from David K. Paylor, 

Director of the Virginia Department of Environmental Quality to 

Air Protection Division Director Diana Esher. 

 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. The Commonwealth of Virginia approved and issued the 

permit on February 11, 2014, to be effective that same day.

 X

3. Evidence that the State has the necessary legal authority under 

State law to adopt and implement the plan.

3. Under the authority of section 10.1-1185 of the Code of 

Virginia.

 X
EPA REQUIREMENT STATE SUBMITTAL (X)

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. The State submittal included the actual permit, consisting of 5

pages, and the Statement of Basis, consisting of 18 pages.

 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. The submittal includes a copy of the Public Participation 

Certification, the newspaper announcing the 30 day public 

comment period and hearing date, time and location and a record 

of the hearing. 

 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. See above information. 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. See above information. X

8. Compilation of public comments and the State's response thereto. 8. The submittal included a record of hearing and public 

participation.

 X
Technical Materials

EPA REQUIREMENT STATE SUBMITTAL (X)

1. Identification of all regulated pollutants affected by the plan. 1. Volatile organic compounds 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. Mondelēz Global LLC, Inc. Richmond Bakery, 6002 S. 

Laburnum Avenue located in Henrico County, Richmond

Ozone Maintenance Area

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. Modification of permit with no changes in emissions.

 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. Modification of permit with no changes in emissions.

 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. NA X

6. Evidence, where necessary, that emission limitations are based on 

continuous emission reduction technology.

6. NA X

7. Evidence that the plan contains emission limitations, work practice 

standards and recordkeeping/reporting requirements, where 

necessary, to ensure emission levels.

7. Contained in Conditions 5through 13 of the submittal. X
EPA REQUIREMENT STATE SUBMITTAL (X)

8. Compliance/enforcement strategies, including how compliance 

will be determined in practice.

8. Contained in Condition 10 of the submittal. X

9. Special economic and technological justifications required by any 

applicable EPA policies. (If a policy is not appropriate, explain why.)

9. NA X

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. NA X