SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST

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

tate of Maryland

April 18, 2008

dments to Regulation 30 under COMAR 26.11.19 and new Chapter COMAR 26.11.35 Regulation .01 to .07. to

ns standards for adhesive application and manufacture and over 40 categories of adhesives, sealant primers

leaning compounds (MD SIP revision # 08-02).

pher Cripps

April 29. 2008.

ials

ACCEPTABLE

A REQUIREMENT STATE SUBMITTAL (L

bmittal from the Governor or his 1. Letter dated April 18, 2008 from Shari T. Wilson, Secretary,

PA approval ofthe plan or revision Maryland Department of the Environment.

ate has adopted the plan in the State code 2. Copy of the final rule published in the April 11, 2008,

or issued the permit, order, consent Maryland Register (Vol. 35, Issue 8, page 809) which

m. That evidence shall include the date establishes an effective date of April 21, 2008 and a copy ofthe

uance as well as the effective date ofthe Notice of proposed Action published in the December 21, 2007

he adoptionlissuance date. edition ofthe Maryland Register (Vol. 34, Issue 26, pages 2298

to 2307).

ate has the necessary legal authority 3. Environmental Article, Title 2, Annotated Code of Maryland

pt and implement the plan. including Sections 1-101, 1-404, 2-201, 2-301 to 2-303, 10-102

and 10-203.

ulation, or document submitted for 4. Copy of the final rule published in the April 11, 2008,

tion by reference into the plan, including Maryland Register (Vol. 35, Issue 8, page 809) which
A REQUIREMENT STATE SUBMITTAL

es made to the existing approved plan, establishes an effective date of April 21, 2008 and a copy ofthe

submittal shall be a copy ofthe official Notice of proposed Action published in the December 21, 2007

ment signed, stamped, dated by the edition ofthe Maryland Register (Vol. 34, Issue 26, pages 2298

ial indicating that it is fully enforceable to 2307).

ctive date of the regulation/document

le, be indicated in the document itself.

ate followed all ofthe procedural 5. Letter dated April 18, 2008 from Shari T. Wilson, Secretary,

ate’s laws and constitution in conducting Maryland Department ofthe Environment.

option/issuance of the plan. —

notice was given ofthe proposed 6. Copy of the notices published in: the December 21, 2007

procedures approved by EPA, including edition of The Baltimore Sun; the December 20, 2007, edition

ofsuch notice. ofThe Washington Post; the December 21, 2007, edition ofthe

Cumberland Times-News; the December 21, 2007 edition of

The Daily and Sunday Times (Salisbury Maryland); and the

December 21, 2007, edition of The Enterprise — St. Mary’s Co. —

blic hearings were held in accordance 7. Copy of Hearing Transcript ofthe Hearing held on January

rovided in the public notice and the 23, 2008.

tution, if applicable. —

ic comments and the State’s response 8. See State submittal — Comments and Response to

Comments. —

regulated pollutants affected by the plan. 1. The revision establishes volatile organic compound (VOC)

emission standards for adhesive and sealants in new Chapter 35

“Volatile Organic Compounds from Adhesives and Sealants” to

COMAR 26.1 1 and amends VOC control regulations in

Regulation .30 in COMAR 26.11.19 “Volatile Organic

Compounds from Specific Processes.”

locations of affected sources including 2. Regulation .30 is part of Chapter 19 “Volatile Organic

nattainment designation ofthe locations Compounds from Specific Processes “to COMAR 26.11 which

tainment plan for the affected area(s). is applicable through-out the State of Maryland — see COMAR

26.1 1.19.02A.(2) in the Maryland SIP (40 CFR 52.1070(c)).

Chapter 35 “Volatile Organic Compounds from Adhesives and
A REQUIREMENT STATE SUBMITTAL

Sealants” is applicable through-out the State of Maryland — see

COMAR26.ll.19.O1A.(1) and (2) of the April 18, 2008,

submittal.

changes in plan allowable emissions 3. The State estimates that the revision will reduce affected

es; estimates of changes in current emissions by 64 to 78 percent which equates to 6.65 tons per

affected sources or, where appropriate, day of VOC emissions statewide relative to 2002 emissions and

es in actual emissions from affected 7.26 tons per day of VOC relative to 2009 projected emissions

ations ofthe differences between certain levels. (Page 4 ofthe MDE’s TSD provided with the April 18,

wable emissions anticipated as a result 2008 submittal.)

-

ation that the national ambient air 4. The plan in Chapter 35 establishes new requirements to

AQS), prevention of significant control VOC emissions from adhesives and sealants in order to

s, reasonable further progress reduce VOC emissions, an ozone precursor, which will

bility, as applicable, are protected ifthe improve air quality under the ozone NAAQS. The revision to

mplemented. Regulation .30 under COMAR 26.11.19: (1) replaces the

definition of “polytetrafluoroethylene” with a definition of

“fluoropolymermaterial” to expand coverage to other

fluoropolymer materials; and, (2) provides conforming

amendments Regulation .30 to clarify which operations are

subject to Regulation .30 and which are subject to the new

Chapter 35.

n required to support the proposed 5. Not applicable. No modeling demonstration was required to

ut data, output data, models used, support the required revision.

ta used, meteorological data used,

offsite data (where used), modes of

ons, and other information relevant to the

acy of the modeling analysis. —

essary, that emission limitations are 6. For the revisions to Regulation .30 under COMAR 26.11.19

mission reduction technology, this is not applicable because the amendments only expands the

scope of the regulation and implements conforming

amendments Regulation .30 to clarify which operations are

subject to Regulation .30 and which are subject to the new
A REQUIREMENT STATE SUBMITTAL

Chapter 35. For the new Chapter 35, the emission limitations

set in terms of fixed physical properties (vapor pressure at 20 0

Celsius) or VOC content for clean-up solvents, VOC content

Limits for adhesive and sealant products or overall control

device efficiency for adhesive and sealant application

applications where nonconforming products are applied/used.

See Sections 26.l1.19.30B. and C. to amended 26.11.19.30 and

see Regulation .04 to 26.11.35.

an contains emission limitations, work 7. Ditto. In addition, see Regulations .02, .05, .06 and .07 to

recordkeeping/reporting requirements, COMAR 26.1 1.35 which established the test methods,

sure emission levels. recordkeeping and reporting requirements, compliance and test

methods and container labeling requirements.

ment strategies, including how 8. Ditto.

ermined in practice.

nd technological justifications required by 9. No special justifications are required.

licies. (If a policy is not appropriate,

uest must be accompanied by a 10. Not applicable because this is not a section 107 request.

onstrating maintenance to the relevant

years after redesignation. =