SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST

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

SIP Submitted by: Maryland Department of the Environment

Date Submitted: June 22, 2011

Subject: Adoption of Control Techniques Guidelines for Drum and Pail Coating

Completeness Review 

Completed by: Irene Shandruk

Date Completed: July 5, 2011

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 June 22, 2011 from Robert M. Summers, 

Secretary, Maryland Department of the Environment, to Shawn 

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. The State has submitted evidence that the regulations were 

adopted and approved in final form on April 14, 2011, with an 

effective date of May 16, 2011.

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; Ch.23, 

Acts of 2006.

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 January 14, 2011, and the final rule was published in 

the Maryland Register on May 6, 2011 with an effective date of 

May 16, 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. Cover letter transmitting the SIP revision dated June 22, 

2011. 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’s web site on January 11, 2011, in The 

Washington Post on January 13, 2011, The Baltimore Sun, and 

The Enterprise on January 14, 2011. A hearing transcript is 

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. Original Transcript of Public Hearing was provided in the 

June 22, 2011 submittal.

X

8. Compilation of public comments and the State's response thereto. 8. No public comments were received. 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), which are precursors of 8-hour 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. 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 plan established requirements to limit 

VOCs from drum and pail coating processes.

 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 amends Regulation .13. This CTG will 

reduce emissions of VOCs from drum and pail coating 

processes, which will aid in the (1) attainment of the 8-hour 

ozone standard, and (2) improvement of 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 required revision. 

 X

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

continuous emission reduction technology.

6. The plan established requirements to limit VOCs from drum 

and pail coating processes.

 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 plan established requirements to limit VOCs from drum 

and pail coating processes, and contains work practice 

standards and recordkeeping/reporting requirements.

 X

8. Compliance/enforcement strategies, including how compliance 

will be determined in practice.

8. The plan established requirements to limit VOCs from drum 

and pail coating processes.

 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