SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST

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

SIP Submitted by: Maryland Department of the Environment

Date Submitted: January 10, 2013

Subject: Adoption of the recommended requirements of the Environmental Protection Agency Control Technique Guidelines for 

Miscellaneous Metal and Plastic Parts by adding new Regulation .27-1 under COMAR 26.11.19 Volatile Organic 

Compounds from Specific Processes.

Completeness Review 

Completed by: Gregory Becoat /s/

Date Completed: April 4, 2013

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 January 10, 2013 from Robert M. Summers, 

Secretary, Maryland Department of the Environment (MDE) to 

Shawn Garvin, Regional Administrator, Environmental 

Protection Agency, Region III.

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 State has submitted evidence that the regulations were 

adopted and approved in final form on October 22, 2012, with an 

effective date of November 12, 2012.

X

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

State law to adopt and implement the plan.

3. The regulations were issued pursuant to Maryland 

Environment Article, §§1-101, 1-404, 2-101 – 2-103, 2-301—2-

303, 10-102, and 10-103, Annotated Code of Maryland; 

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. A copy of the proposed rule was published in the Maryland 

Register on June 15, 2012, and the final rule was published in the 

Maryland Register on November 2, 2012 with an effective date 

of November 12, 2012. The January 10, 2013 submittal from 

MDE included a copy of the actual regulation.

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 include: the letter from Robert M. Summers, 

Secretary, MDE submitted on January 10, 2013; a copy of notice 

printed in the November 2, 2012 edition of the Maryland

Register (Volume 39, Issue 22); and copies and certification of 

public hearing notices. 

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. Notice of public hearing and public comment period was 

published on MDE website from May 11, 2012 – July 18, 2012, 

Maryland Register on June 15, 2012, Baltimore Sun on June 15, 

2012, Washington Post on June 14, 2012, Frederick News-Post

on June 15, 2012, Cumberland Times-News on June 15, 2012, 

Saint Mary’s Enterprise on June 15, 2012, Salisbury Daily Times

on June 15, 2012, and Cecil Whig on June 15, 2012. A hearing 

transcript is also provided.

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. A public hearing was held on July 18, 2012 in accordance 

with State laws as evidenced by hearing transcript and letter 

dated January 10, 2013 from Robert M. Summers, Secretary, 

MDE, to Shawn M. Garvin, Regional Administrator, 

Environmental Protection Agency, Region III.

X

8. Compilation of public comments and the State's response thereto. 8. All public comments received were addressed. X
Technical Materials

EPA REQUIREMENT STATE SUBMITTAL (X)

1. Identification of all regulated pollutants affected by the plan. 1. The submittal identifies volatile organic compounds (VOCs) 

as the regulated pollutant affected by the plan.

 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 Maryland. 

 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 regulation established level of control 

for pleasure craft coating operations recommended by EPA’s 

CTG.

 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 SIP revision consists of adding a new Regulation .27-1 

under COMAR 26.11.19 in order to adopt reasonably available 

control technology (RACT) regulations consistent with the level 

of control recommended by the CTG for Miscellaneous Metal 

and Plastic Parts Coatings. 

 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. 

 X

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

continuous emission reduction technology.

6. Not applicable. X
EPA REQUIREMENT STATE SUBMITTAL (X)

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

standards and recordkeeping/reporting requirements, where 

necessary, to ensure emission levels.

7. The regulation established requirements to limit VOCs from 

pleasure craft coating operations as recommended in EPA’s 

CTG.

 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. 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