UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
REGION
III
1650
Arch
Street
Philadelphia,
Pennsylvania
19103­
2029
SUBJECT:
Technical
Support
Document
for
VA
DEQ
SIP
November
30,
2005
Revision
G04
­
"
NSR
in
the
Ozone
Transport
Region"

FROM:
Sharon
McCauley
Permits
and
Technical
Assessment
Branch
TO:
David
Campbell,
Chief
Permits
and
Technical
Assessment
Branch
TECHNICAL
SUPPORT
DOCUMENT
R03­
OAR­
2005­
VA­
0015
VIRGINIA
SIP
REVISION
G04
I.
BACKGROUND
The
Clean
Air
Act
requires
that
13
states
including
the
District
of
Columbia
submit
revisions
to
their
State
Implementation
Plans
that
will
require
major
new
and
major
modified
sources
of
volatile
organic
compounds
(
VOC)
or
nitrogen
oxides
(
NOx)
to
meet
certain
new
source
review
(
NSR)
requirements
if
they
are
located
(
or
are
proposing
to
locate)
in
the
Ozone
Transport
Region
(
OTR).

Section
184
of
the
CAA
requires
specific
additional
controls
for
all
areas
(
not
only
attainment
areas)
in
the
OTR,
but
also
established
the
Ozone
Transport
Commission
(
OTC)
for
the
purpose
of
recommending
to
EPA
regionwide
controls
affecting
all
areas
in
that
region.
The
OTR
consists
of
the
states
of
Connecticut,
Delaware,
Maine,
Maryland,
Massachusetts,
New
Hampshire,
New
Jersey,
New
York,
Pennsylvania,
Rhode
Island,
Vermont,
and
the
Consolidated
Metropolitan
Statistical
Area
that
includes
the
District
of
Columbia
and
portions
of
Virginia.
The
areas
designated
in
the
Virginia
portion
of
the
OTR
are
Arlington
County,
Fairfax
County,
Loudoun
County,
Prince
William
County,
Stafford
County,
Alexandria
City,
Fairfax
City,
Falls
Church
City,
Manassas
City,
and
Manassas
Park
City.

On
March
28,
2005,
the
Virginia
Department
of
Environmental
Quality
submitted
a
SIP
revision
approval
request
entitled
"
NSR
in
the
Ozone
Transport
Region
(
OTR)".
The
applicable
regulations
for
the
OTR
were
adopted
by
the
Virginia
State
Air
Pollution
Control
Board
on
September
29,
2004.
The
State
amended
its
regulations
to
indicate
that
areas
located
in
the
Virginia
portion
of
the
OTR
must
meet
the
requirements
of
Virginia
Code
Article
9
VAC
5
Chapter
80
(
Permits
for
Major
Stationary
Sources
and
Major
Modifications
Locating
in
Nonattainment
Areas)
as
if
they
were
classified
as
moderate
nonattainment,
except
that
the
threshold
for
major
stationary
sources
of
VOCs
would
be
50
tons
instead
of
100
tons.

2
The
SIP
revision
provides
direction
as
to
what
State
regulations
sources
will
need
to
follow
when
they
are
either
planning
to
locate
in
or
are
already
located
in
the
Virginia
portion
of
the
OTR.
Changes
were
made
to
the
following
State
provisions:
9
VAC­
5­
80­
2000
Applicability
and
9
VAC­
5­
80­
2010
Definitions.

II.
SUMMARY
OF
ACTION
EPA
is
proposing
to
approve
a
State
Implementation
Plan
(
SIP)
revision
submitted
by
the
Commonwealth
of
Virginia.
This
revision
pertains
to
changes
in
the
State's
regulations
that
identify
and
define
the
Ozone
Transport
Region
(
OTR)
locations
in
Virginia.
It
also
informs
sources
that
are
located
in
or
planning
to
locate
in
the
OTR
that
they
must
meet
the
requirements
of
Virginia
Code
Article
9
VAC
5
Chapter
80
(
Permits
for
Major
Stationary
Sources
and
Major
Modifications
Locating
in
Nonattainment
Areas)
as
if
they
were
classified
as
moderate
nonattainment,
except
that
the
threshold
for
major
stationary
sources
of
VOCs
would
be
50
tons
instead
of
100
tons.
The
areas
designated
in
the
Virginia
portion
of
the
OTR
are
Arlington
County,
Fairfax
County,
Loudoun
County,
Prince
William
County,
Stafford
County,
Alexandria
City,
Fairfax
City,
Falls
Church
City,
Manassas
City,
and
Manassas
Park
City.

In
addition,
this
SIP
revision
emphasizes
the
following:

1.
Counties/
Cities
in
Virginia
which
are
designated
attainment
for
ozone
and
are
located
in
the
OTR,
are
required
to
apply
new
source
requirements
to
sources
of
VOC
which
have
the
potential
to
emit
100
tons
per
year
or
more
of
nitrogen
oxides
or
50
tons
per
year
of
Volatile
Organic
Compounds.
Note
that
sources
that
are
located
in
the
OTR
and
are
designated
as
serious
or
severe
are
required
to
meet
the
more
stringent
of
emission
thresholds
listed
within
the
State`
s
definition
of
Major
Stationary
source
at
9­
VAC
5­
80­
2010C
Section
a
(
1)
&
(
2)
based
on
their
nonattainment
status.

2.
Sources
that
are
planning
to
locate
or
are
within
the
Virginia
OTR
are
subject
to
meet
offset
requirements
for
areas
classified
as
moderate
in
9
VAC
5­
80­
2120
B
2.
The
ratio
of
total
emissions
of
volatile
organic
compounds
or
the
ratio
of
total
emission
reductions
of
nitrogen
oxides
to
total
increased
emissions
of
nitrogen
oxides
in
ozone
nonattainment
areas
designated
as
moderate
will
be
1.15
to
one.
3
III.
EVALUATION
Specific
Provision/
Part:
9
VAC
5
Chapter
80­
2000
(
Applicability)
9
VAC
5
Chapter
80
­
2010
(
Definitions)

Analysis
State
Submittal
Approvability
1.
Clarity:
wording
and
intent
are
clear.
9
VAC­
5
Chapter
80
­
2000
B
&
C
X
2.
Breadth/
inclusiveness:
the
reg/
def
is
not
too
narrow
(
covers
all
appropriate
sources).
All
appropriate
sources
identified
2000
B&
C
2010
C.
­
Areas
defined
X
3.
What
sources/
source
categories
are
being
regulated:
Number
and
location(
s).
2010
C.
­
Localities/
Areas
defined
X
4.
Is
the
submitted
regulations
in
compliance
with
the
1990
CAAA?
Yes
X
IV.
CONCLUSION
Per
EPA
review
of
the
State's
request,
an
approved
revision
to
the
SIP
should
be
made
to
reflect
the
revised
provisions
of
the
OTR
designations
in
Virginia's
Code
as
of
September
29,
2004.

V.
RECOMMENDED
AGENCY
ACTION
This
submittal
for
revision
to
the
Virginia
SIP
Revision
#
G04
should
be
approved
and
a
subsequent
notice
of
proposed
rulemaking
be
issued.
