SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST (in accordance with 40 CFR Part 51

- App. V) SI P Submitted by : Mary land Department of the Environment Date Submitted: June 22, 20 11 Subject: Adoption of Control Techniques Guidelines for Drum and Pail Coating Completeness Review Completed by : Irene Shandruk Date Completed: July

5 , 201 1 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. L etter dated June 22, 20 11 from Robert M. Summers , Secretary , Mary land Dep artment 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 th e 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 effec tive 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 Mary land Environment Article, §§1

- 101, 1
- 404, 2
- 101

– 2
- 103, 2
- 301

— 2
- 303 , 10
- 102, and 10

- 103, Annotated Code of Mary land; Ch.23, Acts of 2006. XEPA REQUIREMENT STATE SUBMITTAL (X) 4. A cop y 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 pl an, where applicable. The submittal shall be a copy of the official State regulation/document signed, stamped, dated b y the appropriate State official indicating that it is fully enforceable b y the State. The effective date of the regulation/document sha ll, whenever possible, be indicated in the document itself. 4. A cop y of the proposed rule was published in the Maryland Register on January

14, 2011 , and the final rule was published in the Mary land Register on May 6, 2011 with an effective date of May 1 6, 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, 20 11 . Copies and certification of public hearing notices. X 6. Evidence that public notice was given of the proposed change consistent with procedures approved b y EPA, including the date of publication of such notice. 6. Notice of public hearing and pu blic 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 wer e 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, 20 11 submittal. X 8. Compilation of public comments and the State's response thereto. 8. No public comments were received. XTechnical Materials EPA REQUIREMENT STATE SUBMITTAL (X) 1. I dentification 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. I dentification 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 Mary land. 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 appr opriate, 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 visibilit y, as applicable, are protected if the plan is approved and implemented. 4. The SI P 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 Mary land. X

5. Modeling information required to support the proposed revision, including input data, output data, models used, ambient monitoring data used, meteorological data used, justificat ion for use of offsite data (where used), modes of models used, assumptions, and other information relevant to the determination of adequacy of the modeling analy sis. 5. Not applicable. No modeling demonstration was required to support the required revis ion. 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
. XEPA REQUIREMENT STATE SUBMITTAL (X) 7. Evidence that the plan contains emi ssion 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 b y an y 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 main tenance to the relevant NAAQS for at least 10 y ears after redesignation. 10. Not applicable because this is not a section 107 request. X