  SEQ CHAPTER \h \r 1 SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST

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

 SIP Submitted by:	Delaware Department of Natural Resources and
Environmental Control

 Date Submitted:	May 2, 2007

 Subject:	Regulation No. 1124 – Control of Volatile Organic Compound
Emissions, Section 46 – Crude Oil Lightering Operations

 Completeness Review 

 Completed by:	Rose Quinto

 Date Completed:     May 17, 2007

Administrative Materials

                                                                        
        SEQ CHAPTER \h \r 1 ACCEPTABLE

  SEQ CHAPTER \h \r 1 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 May 2, 2007 from John A. Hughes, Secretary, Delaware Department of
Natural Resources & Environmental Control to Donald S. Welsh, Regional
Administrator.	 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 Order has an issuance date of April
3, 2007, effective date May 11, 2007.  The Order was signed by the
Secretary on April 3, 2007.	 X

3. Evidence that the State has the necessary legal authority under State
law to adopt and implement the plan.	3. Delaware has legal authority to
adopt this RACT certification under Title 7, Delaware Code, Chapter 60.	
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.  Document entitled, “Regulation 1124, Section 46
– Crude Oil Lightering Operations,” effective May 11, 2007.  Cover
letter dated May 2, 2007, transmitting the document has an effective
date of May 11, 2007.	

 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.  Secretary’s Order No. 2007-A-0011
dated April 3, 2007.  Cover letter transmitting the SIP revision dated
May 2, 2007.  Copy of public hearing notices.  Certification of public
hearing notice.	 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.  Affidavit of publications dated October
29, 2006 from two local newspapers: The News Journal and Independent
Newspapers, Inc.	 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.  Certification dated April 27, 2007
signed by the Administrator, Air Quality Management.  Public hearing was
held on December 4, 2006.	 X

8. Compilation of public comments and the State's response thereto.	8. 
Hearing Officer’s Report dated March 23, 2007, Public Hearing Response
Document dated February 27, 2007.	 X





  SEQ CHAPTER \h \r 1 Technical Materials

  SEQ CHAPTER \h \r 1 EPA REQUIREMENT	STATE SUBMITTAL 	(X)

  SEQ CHAPTER \h \r 1 1. Identification of all regulated pollutants
affected by the plan.	1.  Control of VOC from crude oil lightering
operations.	  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.  State of Delaware.	  

  X

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.  Not applicable.  The plan
established requirements to control VOC from crude oil lightering
operations.	  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. 
The plan addresses only nonattainment area pollutants for VOC. 
Therefore, PSD increments and protection (maintenance) of NAAQS are not
applicable.  	  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. 
Not applicable.  No modeling demonstration was required to support the
required revision.  No additional modeling beyond UAM attainment
modeling is needed.	  X

6. Evidence, where necessary, that emission limitations are based on
continuous emission reduction technology.	6. Not applicable.  The plan
established requirements to control VOC emissions from crude oil
lightering operations.	  X

7. Evidence that the plan contains emission limitations, work practice
standards and recordkeeping/reporting requirements, where necessary, to
ensure emission levels.	7. Section 46.4.1.4 – Maximum allowable
uncontrolled lightering volume, Section 46.7 – Record Keeping, Section
46.9 – Reporting Requirements.	  X

8. Compliance/enforcement strategies, including how compliance will be
determined in practice.	8.  Section 46.4 – Compliance Schedule and
Section 46.5 – Compliance Plan.	  X

9. Special economic and technological justifications required by any
applicable EPA policies. (If a policy is not appropriate, explain why.)
9.  No special justifications are required.	  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.  Not applicable because this is not a section
107 request.	  X



