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

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

   SIP Submitted by:     Virginia Department of Environmental Quality

   Date Submitted:        February 11, 2008

   Subject:                     RACT Permit

Completeness Review:  Base File Number:  VA 222

Completed by:	     Ellen Wentworth, 3AP21  /s/

Date Completed:           April 10, 2008 

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 from
David K. Paylor, Director, Virginia Department of Environmental Quality
submitted on February 11, 2008.	 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. Not a regulatory change.  The submittal
is a request to remove an obsolete permit from the SIP.  Once EPA
approves the request, the permit repeal will become effective 30 days
later.	 X

3. Evidence that the State has the necessary legal authority under State
law to adopt and implement the plan.	3. State has the legal under
§10.1-1185 of the Code of Virginia.	 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 submittal is a request to remove an obsolete
RACT permit from the SIP.  Sources at the facility that were previously
subject to NOx RACT permit requirements have shut down.  Mutual shutdown
agreements between the Virginia Department of Environmental Quality and
Norfolk Southern Corporation were submitted as part of the submittal.

	

  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.  Revision submitted pursuant to the
requirements of Section 110 of the CAA.  	 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.  Copy of notice printed in the Roanoke
Times and World News on November 9, 2007 submitted, informing the public
of SIP revision.	 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 that public hearing was
held in accordance with public notice information submitted.	 X

8. Compilation of public comments and the State's response thereto.	8. 
No public comments were received.	 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.  Regulated pollutant-NOx	 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.  Affected sources are
located at the Norfolk Southern Railway Company in Roanoke, Virginia.	  

 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.  VADEQ will remove subject
equipment from the air emissions inventory and will consider its air
pollutant emissions to be zero in any future air quality analysis to be
conducted.	 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.  
Not required (N/R) for RACT.  RACT is setting emission limits based upon
technological & economic feasibility considerations.  This SIP revision
is approving the shutdown of equipment that previously emitted NOx and
as a result, will result in less emissions being released.     	 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.	 X

6. Evidence, where necessary, that emission limitations are based on
continuous emission reduction technology.	6.  Not applicable.  	 X

7. Evidence that the plan contains emission limitations, work practice
standards and recordkeeping/reporting requirements, where necessary, to
ensure emission levels.	7.  Not applicable.	 X

8. Compliance/enforcement strategies, including how compliance will be
determined in practice.	8.  Not applicable.	 X

9. Special economic and technological justifications required by any
applicable EPA policies. (If a policy is not appropriate, explain why.)
9.  Not applicable.	 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 a section 107 request.	 X



