SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST

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

 SIP Submitted by: Maryland Department of the Environment

 Date Submitted: May 8, 2012

 Subject: Revision of Regulation .23 “Control of VOC Emissions from Vehicle Refinishing” under COMAR 26.11.19

Completeness Review 

Completed by: Emlyn Vélez-Rosa

 Date Completed: June 5, 2012

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. A letter dated May 2, 2012 was submitted by Robert M. 

Summers, Secretary of the Maryland Department of the 

Environment (MDE).

X

2. Evidence that the State has adopted the plan in the State code 

or body of regulations; or issued the permit, order, or 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.

Check to see if the regulation, permit, order or consent decree 

has a sunset or expiration date. If so it is not acceptable as a 

SIP submission. 

2. MDE provided a copy of the Notice of Final Action for the 

Regulation .23 under COMAR 26.11.19 in the Maryland 

Register, Volume 39, Issue 7, dated April 6, 2012. According 

to the notice provided, the Secretary of the Environment 

adopted the appeal of existing regulation and the new 

regulation on March 26, 2012. The effective date of this final 

action is April 16, 2012.

X

3. Evidence that the State has the necessary legal authority 

under State law to adopt and implement the plan.

3. The State of Maryland has legal authority under the 

Environmental Article, Title 2 Annotated Code of Maryland.

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 

4. MDE included: a copy of the final rule in document entitled 

“Final text COMAR 26.11.19.23, effective April 16, 2012.” X
EPA REQUIREMENT STATE SUBMITTAL (X)

by the State. The effective date of the regulation/document 

shall, whenever possible, be indicated in the document itself.

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 letter of submittal dated May 2, 2012 signed by Robert 

M. Summers, Secretary of the MDE, certifies that all state 

procedural requirements were followed in the adoption of this 

plan revision.

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 of public hearing, as published on MDE’s 

website on December 8, 2011, and a certificate of publication 

of such notice dated December 9, 2011, signed by Diana 

Alegre, MDE’s Webmaster.

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. Certified transcript of the public hearing held on January 11, 

2012, and the letter of submittal dated May 2, 2012, signed by 

Robert M. Summers, Secretary of the MDE, certifies that all 

state procedural requirements were followed in the adoption of 

this plan revision.

X

8. Compilation of public comments and the State's response 

thereto.

8. Copy of comment letter dated January 11, 2012, and a 

compilation of public comments and MDE’s responses.

X

 Technical Materials

1. Identification of all regulated pollutants affected by the plan. 1. Control of Volatile Organic Compounds (VOCs) emissions 

from coatings and cleaning solvents used during the 

preparation, application, and drying phases of vehicle 

refinishing.

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. SIP revision applies to all vehicle refinishing facilities in the 

entire 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 

3. The plan established requirements to limit volatile organic 

compounds (VOC) content by coating category.

X
EPA REQUIREMENT STATE SUBMITTAL (X)

baseline levels and allowable emissions anticipated as a result 

of the revision.

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 regulation amendments to limit 

VOC emissions in order to contribute to (1) attainment and 

maintenance of the 8-hour ozone standard, and (2) 

improvement of the ambient air.

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

7. Evidence that the plan contains emission limitations, work 

practice standards and recordkeeping/reporting requirements, 

where necessary, to ensure emission levels.

7. The proposed SIP revision establishes emission limitations, 

work practice standards and recordkeeping/reporting 

requirements, for controlling VOC emissions.

X

8. Compliance/enforcement strategies, including how 

compliance will be determined in practice.

8. The proposed SIP revision includes compliance and 

enforcement requirements.

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. Not a Section 107 request. X