  SEQ CHAPTER \h \r 1 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 31, 2006 and July 5, 2006

Subject: SIP Revision 06-04 RACT for VOC’s from medical device
manufacturing 

Completeness Review

Completed by: Helene Drago

Date Completed: July 17, 2006

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 May 31, 2006 and supplemental letter dated July 5, 2006 from Kendl
P. Philbrick, Secretary, Maryland Department of the Environment, to
Donald Welsh, Regional Administrator, EPA Region III.	 Yes

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 regulations were adopted on May 11,
2006 and published in the Maryland Register on May 26, 2006 with an
effective date of June 5, 2006.  An Errata to the regulation was
published in the Maryland Register on May 12, 2006.	 Yes

3.  Evidence that the State has the necessary legal authority under
State law to adopt and implement the plan.	3.  Environmental Article,
Title 2, Annotated Code of Maryland.	 Yes

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.  MDE submitted 1) a copy of the proposed rule
published in the Maryland Register on March 3, 2006, 2) an Errata to the
regulation published in the Maryland Register on May 12, 2006. and 3)
the final rule published in the Maryland Register on May 26, 2006 with
an effective date of June 5, 2006.  	Yes

 

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.  Letter dated May 31, 2006 and
supplemental information submitted July 5, 2006, from Kendl P.
Philbrick, Secretary, Maryland Department of the Environment.	Yes

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 hearing notices in Maryland
Register, and The Cecil Whig on March 3, 2006.  Copy of hearing
transcripts, attendance sign-in sheets.	Yes

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.  Letter dated May 31, 2006, from Kendl
P. Philbrick, Secretary, Maryland Department of the Environment. 
Certified transcript of public hearing with attendance sign-in sheets
date April l5, 2006.	Yes

8.  Compilation of public comments and the State's response thereto. 	8.
 Certified transcript of Public Hearings with copies of public comments
and state response to comments	Yes



Technical Materials

EPA REQUIREMENT	STATE SUBMITTAL 	(X)

1.  Identification of all regulated pollutants affected by the plan.	1.
VOC’s	Yes

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.Cecil County,
Maryland	

  Yes

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.  There is one effected
source in Cecil County, Md.  It is estimated that as a result of this
proposed regulation approximately 2 tons of VOC emissions per year will
be reduced. 	 Yes

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 applicable 

	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.
State provided an itemized 2004 emissions summary of the medial facility
that will be effected by this regulation.  	Yes

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

	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. Regulation states all those subject to
controls for medical device manufacturing are subject to COMAR
26.11.19.02 - Applicability, determining compliance, reporting and
general requirements	Yes

8. Compliance/enforcement strategies, including how compliance will be
determined in practice.	8..Regulation states all those subject to
controls for medical device manufacturing are subject to COMAR
26.11.19.02 - Applicability, determining compliance, reporting and
general requirements	Yes

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

	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

	

