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 th e Commonwealth of Virginia ’s Control of Emissions of Volatile Organic Compounds From Mondel ē z 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. L etter 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, 201 4 , 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. XEPA REQUIREMENT STATE SUBMITTAL (X)

4. A c opy 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 regula tion/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 submitt al included the actual permit, consist ing of 5

pages
, and the Statement of Basis, consist ing 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 adop tion/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 t he hearing

. X

6. Evidence that publi c 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 provi ded 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

. XTechnical 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 B akery, 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 revisi on. 3. Modification of permit with no changes in emission s

. X

4. The State's demonstration that the national ambient air quality standards, prevention of significant deterioration increments, reasonable further progress demonstration, and visibility, a s applicable, are protected if the plan is approved and implemented. 4. Modification of permit with no changes in emission s

. 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. Contai ned in Conditions 5 through 1 3 of the submittal. XEPA REQUIREMENT STATE SUBMITTAL (X)

8. Compliance/enforcement strategies, including how compliance will be determined in practice. 8. Contained in Condition 1 0 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