SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST

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

SIP Submitted by: Maryland Department of the Environment

Date Submitted: December 15, 2011

Subject: Revision #11-09 for the incorporation of Control Technique Guidelines for lithographic and letterpress printing by U.S. 

EPA into Maryland’s Regulation (COMAR 26.11.19)

Completeness Review 

Completed by: Asrah Khadr 

Date Completed: January 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. Letter dated December 15, 2011 from Robert M. Summers 

Ph.D., Secretary, Maryland Department of the Environment to 

Shawn M. Garvin, 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. Final Action on Regulations was published in the Maryland 

Register on October 21, 2011. The revision to Regulation .11 

under COMAR 26.11.19 - Volatile Organic Compounds from 

Specific Processes was adopted by the Secretary of the 

Environment on October 4, 2011 and became effective on 

October 21, 2011. 

X

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

State law to adopt and implement the plan.

3. Maryland has the legal authority to adopt and implement the 

plan under 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 Volume 38, Issue 12 of the Maryland Register 

(April 22, 2011), shows Regulation 0.11 of COMAR 26.11.19 

with proposed revisions. Copy of Volume 38, Issue 12 of the 

Maryland Register (October 21, 2011) finalizes the previously 

proposed regulation and shows minor revisions made to the 

proposed Regulation. The revision was adopted by the Secretary

of the Environment on October 4, 2011 and became effective on 

October 21, 2011. 

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. A letter from Linda C. Janey, J.D., Assistant Secretary for 

Clearinghouse and Communications affirming that amendments 

to Regulation 0.11 under COMAR 26.11.19 met all requirements 

in accordance with COMAR 34.02.01.04-.06.

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. Certificate of publication certifying that a notice of public 

hearing appeared on the MDE website. Notice of public hearing 

also appeared in emails to interested parties, and in the correction 

of hearing date published in Volume 38, Issue 12 of the 

Maryland Register (June 3, 2011). 

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. Hearing statement by the Air and Radiation Management 

Administration of the MDE affirming that state and federal laws 

were met at the public hearing. 

X

8. Compilation of public comments and the State's response thereto. 8. Hearing Transcript provided as well as a copy of the public 

comments received and the responses thereto.

X
Technical Materials

EPA REQUIREMENT STATE SUBMITTAL (X)

1. Identification of all regulated pollutants affected by the plan. 1. The submittal identifies VOCs which are a precursor to 

ozone.

 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. This regulation regulates VOCs, hence there are no 

attainment/nonattainment designations of locations and no 

attainment plan. The affected area is 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, implementation of EPA’s Control Technique 

Guidelines for lithographic and letterpress printing into 

Maryland’s Regulations. 

 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 amendments to Regulation 0.11 

under COMAR 26.11.19 regarding addition of EPA’s Control 

Technique Guidelines for lithographic and letterpress printing 

which will assist with the attainment of the ozone National 

Ambient Air Quality Standard (NAAQS) and improve the 

ambient air quality in Maryland. 

 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 revision. 

 X

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

continuous emission reduction technology.

6. The plan includes air pollution control devices as part of 

VOC emissions control. 

 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 amendments established emissions limitations for VOCs 

as well as work practice standards and recordkeeping/reporting 

requirements. 

 X

8. Compliance/enforcement strategies, including how compliance 

will be determined in practice.

8. The amendments discuss compliance strategies for the 

emissions limitations for VOCs.

 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