SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST (in accordance with 40 CFR Part51 -App. V) SIP Submitted by: State of Maryland Date Submitted: April 18, 2008 Subject: Amendments to Regulation 30 under COMAR 26.11.19 and new Chapter COMAR 26.11.35 Regulation .01to.07.to establish VOC emissions standards for adhesive application and manufacture and over 40 categories of adhesives, sealant primers adhesive primers and cleaning compounds (MD SIP revision # 08-02). Completeness Review Completed by: Christopher Cripps Date Completed: April 29. 2008. Administrative Materials ACCEPTABLE EPA REQUIREMENT STATE SUBMITTAL (L 1.A formal letter of submittal from the Governor orhis 1. Letter dated April 18, 2008 from Shari T. Wilson, Secretary, designee, requesting EPA approval ofthe plan or revision Maryland Department ofthe Environment.

:hereof.2. Evidence that the State has adopted the plan inthe State code 2. Copy ofthe final rule published inthe April 11, 2008, rbody of regulations; or issued the permit, order, consent Maryland Register (Vol. 35, Issue 8, page 809) which agreement in final form. That evidence shall include the date establishes an effective date of April 21, 2008 andacopy ofthe )f adoption or final issuance as well asthe effective date ofthe Notice of proposed Action published inthe December 21, 2007 ,lan, if different from the adoptionlissuance date. edition ofthe Maryland Register (Vol. 34, Issue 26, pages 2298 to 2307). 3. Evidence that the State has the necessary legal authority 3. Environmental Article, Title 2, Annotated Code of Maryland inder State lawto adopt and implement the plan. including Sections 1-101, 1-404, 2-201, 2-301 to 2-303, 10-102 and 10-203. I..A copy of actual regulation, or document submitted for 4. Copy ofthe final rule published inthe April 11, 2008, tpproval and incorporation by reference into the plan, including Maryland Register (Vol. 35, Issue 8, page 809) whichEPA REQUIREMENT STATE SUBMITTAL indication ofthe changes made tothe existing approved plan, establishes an effective date of April 21, 2008 andacopy ofthe vhere applicable. The submittal shall beacopy ofthe official Notice of proposed Action published inthe December 21, 2007

State regulation/document signed, stamped, dated bythe edition ofthe Maryland Register (Vol. 34, Issue 26, pages 2298 appropriate State official indicating thatitis fully enforceable to 2307). )the State. The effective date ofthe regulation/document shall, whenever possible, be indicated inthe document itself. 5. Evidence that the State followed allofthe procedural 5. Letter dated April 18, 2008 from Shari T. Wilson, Secretary, equirements ofthe State’s laws and constitution in conducting Maryland Department ofthe Environment. and completing the adoption/issuance ofthe plan. —

6. Evidence that public notice was given ofthe proposed 6. Copy ofthe notices published in:the December 21, 2007 change consistent with procedures approved by EPA, including edition ofThe Baltimore Sun; the December 20, 2007, edition he date of publication of such 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 ofThe Enterprise —St. Mary’s Co. — 7. Certification that public hearings were held in accordance 7. Copy of Hearing Transcript ofthe Hearing held on January vith the information provided inthe public notice and the 23, 2008. State’s laws and constitution, if applicable. — 8. Compilation of public comments and the State’s response 8.See State submittal — Comments and Response to hereto. Comments. — 1. Identification ofall regulated pollutants affected bythe 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 26.11and amends VOC control regulations in Regulation .30in COMAR 26.11.19 “Volatile Organic Compounds from Specific Processes.” 2. Identification ofthe locations of affected sources including 2. Regulation .30ispart of Chapter 19 “Volatile Organic he EPA attainment/nonattainment designation ofthe locations Compounds from Specific Processes “to COMAR 26.11 which ‘md the status ofthe attainment plan forthe affected area(s). is applicable through-out the State of Maryland —see COMAR 26.1 1.19.02A.(2) inthe Maryland SIP (40 CFR 52.1070(c)). Chapter 35 “Volatile Organic Compounds from Adhesives andEPA REQUIREMENT STATE SUBMITTAL Sealants” is applicable through-out the State of Maryland —see COMAR26.ll.19.O1A.(1) and (2)ofthe April 18, 2008, submittal. 3. Quantification ofthe changes in plan allowable emissions 3. The State estimates that the revision will reduce affected from the affected sources; estimates of changes in current emissions by64to78 percent which equates to 6.65 tons per actual emissions from affected sources or, where appropriate, dayof VOC emissions statewide relative to 2002 emissions and luantification of changes in actual emissions from affected 7.26 tons per dayof VOC relative to 2009 projected emissions sources through calculations ofthe differences between certain levels. (Page 4ofthe MDE’s TSD provided with the April 18, aseline levels and allowable emissions anticipated asa result 2008 submittal.) ifthe revision. - LThe Stat&s demonstration that the national ambient air 4. The plan in Chapter 35 establishes new requirements to quality standards (NAAQS), prevention of significant control VOC emissions from adhesives and sealants in order to deterioration increments, reasonable further progress reduce VOC emissions, an ozone precursor, which will demonstration, and visibility, as applicable, are protected ifthe improve air quality under the ozone NAAQS. The revision to )lanis approved and implemented. Regulation .30 under COMAR 26.11.19: (1) replaces the definition of “polytetrafluoroethylene” witha definition of “fluoropolymermaterial” to expand coverage to other fluoropolymer materials; and, (2) provides conforming

amendments Regulation .30to clarify which operations are subject to Regulation .30 and which are subject tothe new Chapter 35. 5. Modeling information required to support the proposed 5. Not applicable. No modeling demonstration was required to evision, including input data, output data, models used, support the required revision. ambient monitoring data used, meteorological data used, ustification foruseof offsite data (where used), modes of nodels used, assumptions, and other information relevant tothe Jetermination of adequacy ofthe modeling analysis. — 5. Evidence, where necessary, that emission limitations are 6.For the revisions to Regulation .30 under COMAR 26.11.19 )ased on continuous emission reduction technology, thisisnot applicable because the amendments only expands the scope ofthe regulation and implements conforming amendments Regulation .30to clarify which operations are subject to Regulation .30 and which are subject tothe newEPA REQUIREMENT STATE SUBMITTAL Chapter 35. For the new Chapter 35,the emission limitations setin terms of fixed physical properties (vapor pressure at20 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. andC.to amended 26.11.19.30 and see Regulation .04to 26.11.35. 7. Evidence that the plan contains emission limitations, work 7. Ditto. In addition, see Regulations .02, .05, .06 and .07to )ractice standards and recordkeeping/reporting requirements, COMAR 26.1 1.35 which established the test methods,

vhere necessary, to ensure emission levels. recordkeeping and reporting requirements, compliance and test methods and container labeling requirements. 8. Compliance/enforcement strategies, including how 8. Ditto. Dompliance will be determined in practice. . Special economic and technological justifications required by9.No special justifications are required. any applicable EPA policies. (Ifa policy isnot appropriate, explain why.) 10.A Section 107 request must be accompanied bya 10. Not applicable because thisisnota section 107 request. naintenance plan demonstrating maintenance tothe relevant ‘4AAQS forat least 10 years after redesignation. =