Debbie Rabin - New CEMS regulation - COMAR 26.11.01.11 

From: 

To: 

Date: 

Subject: 

"McLain, Steve" <SMclain@pandamd.com> 

"Roland Gorschboth" <rgorschboth@mde.state.md.us> 

2/1 5/2011 2:20PM 

New CEMS regulation - CO MAR 26.11.01.11 

Page 1 of 1 

Attachments: Existing section 1 O.pdf; Existing section ll.pdf; Old CEMS regulation re opacity data 

handling.pdf; Proposed section 11.pdf 

Hello Roland, 

We at Panda have noted that the MOE is making changes to COMAR in regard to CEMS and COMS regulations. It 

appears that the primary focus of the MOE has been on splltting the requirements for the two different types of 

systems Into two separate sect ions. 

The original version of COMAR 26.11.01.10 applied to both opacity and emission monitoring systems. In that 

version, under 26.11.01.10, G., (2), (a), it was specifically stated that "An opacity CEM shall automatically reduce 

all data to 6-minute block averages ... " Since that time, sections .10 and .11 were heavily modified, with .10 

becoming the body of regulations applicable to COM systems, and .11 becoming those regulations applicable to 

CEM systems. 

In the existing (just prior to the latest COMAR changes to the section) version of COMAR 26.11.01.11, i.e. those 

regulations applicable to emissions monitoring systems, the only reference t o data reduction is under section D., 

(2), which states that "A CEM .. shall record four equally spaced data points per hour and automatically reduce 

data in terms of averaging times consistent with the applicable emission standard." The requirement for 6-

minute data reduction algorithm was kept in the existing version of 26.11.01.10, which applies to opacity 

monitoring systems, under D., (2), i.e. '6-minute averaging for 24 or more ... points.' 

The most recent change to 26.11.01.11 (emissions systems) made by the MOE adds a new section E. to .11, 

including an item (2), which adds a requirement for the 6-minute averaging of data, although section 0.(2), 

referring to '4 equally spaced points' is left unchanged. This appears to create a conflict. 

I have attached relevant highlighted portions of COMAR for your review. 

My CEMS vendor has expressed a doubt that the MOE intended the 6-minute averaging requirement to apply to 

CEM systems in addition to COM systems. Would you please confirm for me that the latest revision to 

26.11.01.11 is indeed correct, i.e. that 6-minute averaging is to be applied to the data recorded by a Continuous 

Emissions Monitoring System? Panda is striving to comply as best it can. 

Thank you, 

Steven M. McLain, P .E. 

Plant Engineer 

Panda Brandywine, LP 

16400 M attawoman Drive 

Brandywine, Maryland 20613 

smclain@panqa,tnd.com 

301-782-4000 

file://C:\Documents and Settings\drabin\Local Settings\ Temp\XPgrpwise\4050411 AMDE... 7/28/2011 
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16.11.01.11 e~ \s-ri" r-J" . 

@=ontinuous iss~~ Monitoring Requirements. 

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A. Applicability and Exemptions. 

(I) The provisions of this regulation apply to: 

(a) Fuel-burning equipment burning coal that has a rated heat input capacity of 100 million Btu per hour or greater; 

(b) Municipal waste combustors with a burning capacity greater than 35 tons per day; 

(c) Fluidized bed combustors; and 

(d) Kraft pulp mills. 

(2) An owner or operator that is required to install a CEM under any federal requirement is also subject to all of the 

provisions of this regulation. 

B. General Requirements for CEMs. 

(I) An owner or operator subject to this regulation shall: 

(a) Before installing a CEM, submit to the Department, for approval by the Department and EPA, a plan containing 

the CEM design specifications, proposed location, and a description ofa proposed alternative measurement method; and 

(b) Install and operate a CEM in accordance with the plan approved by the Department and EPA under the provisions 

of §B(l)(a) of this regulation. 

(2) The owner or operator of fuel-burning equipment burning coal, with a heat input capacity of I 00 million Btu per 

hour or greater, shall install CEMs to measure and record sulfur dioxide, nitrogen oxide, either oxygen or carbon dioxide, and 

flow. 

(3) The owner or operator of: 

{a) A municipal waste combustor {MWC) shall install a CEM in accordance with the requirements in COMAR 

26.11.08.07 or COMAR 26.11.08.08, as applicable; 

(b) A Kraft pulp mill shall install a CEM to measure and record process total reduced sulfur in accordance with 

COMAR 26.11.14.05; and 

(c) A fluidized bed combustor of any size shall install CEMs to measure sulfur dioxide, nitrogen oxide and either 

oxygen or carbon dioxide. 

(4) Except as otherwise approved by the Department, if the owner or operator is unable to obtain emissions data from 

CEMs because of a malfunction of the CEM for more than 2 hours in duration, the owner or operator shall use the alternative 

measurement method approved by the Department and EPA. 

C. Quality Assurance for CEMs. A CEM used to monitor a gas concentration shall meet the quality assurance criteria of 40 

CFR Part 60, ~ppendix F, as amended, which is incorporated by reference, or, if applicable, the quality assurance criteria of 

40 CFR Part 75, Appendix B, as amended. 

~onitoring and rmining Compliance. 

(1) General. A CEM required by this regulation is the primary method used by the Department to determine compliance 

http://www.dsd.state.md.us/comar/comarhtml/26/26.11.01.1l.htm 2/15/2011 
Page 2 of2. 

or non-compliance with the applicable emission standards established in any penn it or approval, administrative or court 

order, Certificate of Public Convenience and Necessity, or regulation in this subtitle. 

(3) Technical Memorandum. Except for fuel burning equipment subject to the COM requirements in CO MAR 

26.11.09.05, usc of COMs and CEMs for enforcement purposes shall be as specified in the Department's Air Management 

Administration Technical Memorandum 90-01 "Continuous Emission Monitoring (CEM) Policies and Procedures," which is 

incorporated by reference. 

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http://www.dsd.state.md.us/comar/comarhtmV26126.ll.Ol.ll.htm 2/1512011 

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161.1.01.10 f" ')<. ,~,, ,J~ (3:ontinuous ~aeity Monitoring Requirements. 

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A. Applicability and Exceptions. 

(I) The provisions of this regulation apply to: 

(a) Fuel burning equipment burning coaJ, fuel oil, tars, or waste combustible fluid at any time and that has a rated heat 

input capacity of2SO million Btu per hour or greater; 

(b) Fuel burning equipment burning coal with a rated heat input capacity of 100 million Btu per hour or greater but 

less than 2.50 million Btu per hour and was constructed on or before June 19, 1984; 

(c) A cement kiln; 

(d) A fluidized bed combustor of any size; and 

(e) A municipal waste combustor with a burning capacity greater than 35 tons per day. 

(2) The owner or operator of an installation subject to this regulation may also be subject to the requirements of 40 CFR 

Parts 60 and 75, as amended. 

(J) This regulation does not apply to fuel burning equipment that: 

(a) Bums only distillate fuel oil or a mixture of gas and distillate fuel oil; 

• . (b) Is able to comply with the applicable particulate matter and opacity emission limitations without using particulate 

- - matter control equipment; and 

(c) Has never been found in a final order to be in violation of any visible emissions standard. 

(4) The owner or operator of fuel burning equipment subject to this regulation may. with approval by the Department, 

discontinue use ofa COM only in accordance with lhe provisions in COMAR 26.11.09.0SC. 

B. General Requirements for COMs. 

( 1) The owner or operator of an installation subject to this regulation shall: 

(a) Install and continuously operate a COM that complies with a plan approved by the Department and EPA in 

accordance with §B(l)(b) of this regulation; and 

(b) Before installing a COM, submit to the Department for approval, a plan containing the COM design specifications, 

proposed location, and a description of a proposed alternative measurement method consisting of a schedule for utilizing the 

EPA Reference Method 9 observational procedures. 

(2) The Department shall submit the plan to EPA for review and approval. 

(3) A COM shall comply with the applicable requirements in 40 CFR Part 51. Appendix P, Sections 3.3-3.9, as 

amended, which is incorporated by reference. 

( 4) The owner or operator of fuel burning equipment that is required by this regulation to install and operate a COM is 

subject to the provisions in COMAR 26.1 1.09.05. 

C. Certification and Quality Assurance Procedures. 

http://www.dsd.state.md.uslcomar/comarhtml/26/26. I 1.0 1.1 O.htm 2115/2011 
26.11.0 1.1 0 Page 2 of3, 

(I) All certification testing, including certification performance tests and audits, shall be performed in accordance with 

40 CFR Part 60, Appendix B, as amended, which is incorporated by reference. 

(2) For fuel burning equipment subject to the federal Acid Rain Program, all certification testing, including certification 

performance tests and audits, shall be performed in accordance with 40 CFR Part 75, Appendix A, as amended. 

(3) Certification testing shall be repeated when the Department determines that the data are invalid because of 

component replacement or other conditions that affect the accuracy of generated data. 

(4) The owner or operator that is required to perfonn a certification performance test shall: 

(a) At lellSt 60 dnys before the test, submit a test protocol to the Department for review and approval; 

(b) Schedule the test at a reasonable time and notify the Department nt least 10 days before the test is to be conducted~ 

and 

(c) Submit the test results to the Department not later than 45 days after the completion of the test 

(5) Fuel burning equipment subject to the COM requirements in COMAR 26.11.09 shall meet the quality assurance 

procedures contained in Technical Memorandum 90-0l"Continuous Emission Monitoring (CEM) Policies and Procedures," 

Part II Quality Assurance Requirements for Continuous Opacity Monitoring Systems. 

@cord Koeping and Reporting Rcquiromenb. 

(l) System Downtime Reporting Requirements. 

(a) All COM downtime that lasts or is expected to last more than 24 hours shall be reported to the Department by 

telephone before 10 a.m. of the first regular business day following the first day on which downtime occurs. 

(b) The COM downtime report shall include the reason, if known, for the breakdown and the estimated period of time 

that the COM will be down. The owner or operator shall notify the Department by telephone when the COM has met 

performance specifications for accuracy, reliability, and durability of acceptable monitoring systems, as provided in 40 CFR 

Part 51 Appendix P, and is producing data. 

(c) Except as otherwise approved by the Department and the EPA, a COM shall operate in compliance with the 

requirements of §8(2) of this regulation and collect data for at least 95 percent of the source's operating time during any 

calendar quarter. The alternative measurement plan required in §B(l)(b) of this regulation shall be used at all times when the 

COM f: confonn to performance standards required by §B(2) of this regulation during data collection. 

(b) All COM data shall be reported in a format approved by the Department. 

(c) A quarterly summary report shall be submitted to the Department not later than 30 days following each calendar 

quarter. The report shall be in a format approved by the Department, and shall include the following: 

(i) The cause, time periods, and the opacity of all emissfons which exceed the applicable quarterly, daily and hourly 

emission standards as provided in COMAR 26.11.09.05A(4); 

(ii) The COM and installation downtimes, including the time and date of the beginning and end of each downtime 

period, and whether the downtime was scheduled; 

(iii) The cause of all COM downtime; 

http://www.dsd.state.md.us/comar/comarhtml/26/26.11.0 1.1 O.htm 2/15/2011 

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26.11.01.10 

operating procedures are being utilized by source operators to maintain emission levels at or below emission standards. 

G. Record Keeping and Reporting Requirements. 

(1) CEM System Downtime Reporting Requirements. 

(a) All CEM system downtime that lasts or is expected to last 

more than 24 hours shall be reported to the Department by t elephone 

before 10 a.m. of the first regular business day following the breakdown. 

(b) The system breakdown report required by §G(l)(a) of this 

regulation shall include the reason, if known, for the breakdown and 

the estimated period of time that the OEM will be down. The owner or 

operator of the CEM shall notify the Department by telephone when 

an out-of-service OEM is back in operation and producing valid data. 

_ 2) ata Repqrting Re ents _ ------- ....--- _ 

( 

(a) An o acity OEM shall automatically reduce all data to \ 

S.mi ~ blocJt averages calculated from 36 or more equally spaced 1 

data pomts. _ __ --------- __ 1 

- (b) ( test results shall be reported in a format approved by 

the Department. 

(c) Certification testing shall be repeated when the Department determines that the OEM data may be invalid because of component replacement or other conditions that affect the quality of 

generated data. 

(d) A quarterly summary report shall be submitted to the 

Department not later than 30 days following each calendar quarter. 

The report shall be in a fonnat approved by the Department, and 

shall include the following: ' 

(i) The cause, time periods, and magnitude of all emissions 

which exceed the applicable emission standards; 

(ii) The source downtime including the time and date of the 

beginning and end of each downtime period and whether the source 

downtime was planned or unplanned; ' 

(Hi) The time periods and cause of all OEM downtime including records of any repairs, a(ijustmente, or maintenance that may 

affect the validity of emisaion data; 

(iv} Quarterly totals of excess emissions, installation downtime, and OEM downtime during the calendar quarter; 

653-2 

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RICH AND HENDERSONt P.C. 

TEL :(410) 267-5900 

TOLL FREE: (800) 407-0250 

VIA U.S. MAIL AND EMAIL 

ATTORNEYS AT LAW 

51 Franklin Street, Suite 300 

P.O. Box S89 

Annapolis, Maryland 21404-0589 

February 15,2011 

Deborah Rabin, Regulations Coordinator 

Air and Radiation Management Administration 

Maryland Department of the Environment 

1800 Washington Boulevard, Suite 730 

Baltimore, Mary land 21230 

RE: Comments on Notice of Proposed Action 

FAX: (410)267-5901 

E-MAIL.: thcnderson@richlaw.com 

Regarding Fuel Burning Equipment Using Continuous Opacity Monitors 

To Comply with Visibility and Opacity Standards 

Dear Ms. Rabin: 

I am writing on behalf of Lehigh Portland Cement Company LLC ("Lehigh") regarding the 

Maryland Department of the Environment's (the "Department") Notice of Proposed Action to 

Amend Regulations .10 and .11 under COMAR 26.11.01, and Regulations .01 and .05 under 

COMAR 26.11.09, and to repeal and amend certain provisions of CO MAR 26.11.31, which was 

published in the January 14,2011, Maryland Register. Md. Reg. Vol. 38, Issue 2, pp. 104-106, and 

1 21-125. (collectively, the "Proposed Regulations"). Lehigh understands that the primary purpose 

of the proposed regulations is to adopt and incorporate the procedures for demonstrating compliance 

in the Department's Technical Memorandum 90-01 into the regulations governing visible emissions 

from facilities using continuous opacity monitoring ("COM") equipment. In general, Lehigh 

supports the Department's efforts. 

Lehigh, however, has concerns that the COM provisions in the Proposed Regulations create 

a potential conflict with the particulate monitoring and compliance requirements imposed on 

Lehigh's Union Bridge Plant by EPA's recent amendments to the National Emission Standards for 

Hazardous Air Pollutants from the Portland Cement Manufacturing Industry and Standards of 

Performance for Portland Cement Plants. 75 Fed. Reg. 54970 (Sept. 9, 2010), as amended by 76 

Fed. Reg. 2832 (Jan. 18, 2011) (collectively, the "New Portland Cement NESHAP"). Through these 

comments, Lehigh seeks to alert the Department to the potential for the conflict, to encourage the 

Department to accommodate the foiJowing concerns and to suggest a solution. 
The New Portland Cement NESHAP imposes very stringent particulate standards and 

continuous emissions monitoring ("CEM'') requirements with which Lehigh's Union Bridge facility 

must comply by September 9, 2013. 40 C.F.R. §63.1343. Compliance with these standards will 

require the Union Bridge facility to install expensive particulate controls and a CEM system to 

measure compliance with the standard. Once installed, these CEMs will render the need tbr COMs 

to monitor compliance with the state and federal opacity standards and the Maryland visibility 

standard, obsolete. EPA acknowledged this fact in the preamble to the Federal Register notice for 

the proposed New Portland Cement NESHAP, stating that "we would also remove the opacity 

standard and opacity continuous monitoring requirements for any source that was PM CEMS ... to 

detenninecompliance with a PM standard." 74 Fed. Reg. 21136,21157. EPA confirmed this in the 

Federal Register notice for the final rule, stating "any kiln or clinker cooler that uses a PM CEMS to 

monitor compliance with the PM emission limit is exempt from opacity standards." 75 Fed. Reg. 

54970, 54989. 

Lehigh encourages the Department to incorporate the necessary flexibility into its opacity and 

visibility regulations to allow Lehigh•s Union Bridge facility to transition from the use ofCOMs for 

measuring compHance with opacity and visibility standards, to using CEMs installed to meet the new 

particulate standard. Lehigh anticipates that it will install those CEMs by the summer of2013. It 

seeks assurance from the Department that once the Union Bridge facility has installed and certified 

the CEMs, that the state regulations would allow it to retire the CO Ms. 

Specifically, Lehigh proposes the addition of the following revision to Regulation . 10 of 

COMAR 26.11.01: 

.1 0 Continuous Opacity Monitoring Requirements. 

A. Applicability and Exceptions. 

(1) The provisions of this regulation apply to the following eguipment to 

the extent it utilizes continuous opacity monitors to assure compliance 

with visibility and opacity requirements: 

This simple change should provide the flexibility which Lehigh requests. 

Lehigh understands that the Proposed Maryland Regulations on which it is commenting are 

intended, in part, to provide opacity procedures for portland cement plants in order to remove "'the 

applicability of TM 90·01 for COMs". Md. Reg., Vol. 38, Issue 2 at p. 104. Lehigh further 

understands that the regulation the Department submitted to the Air Quality Control Advisory 

Council for review and approval on January 31, 2011 by the Department, (to create a new chapter 30 

in the Maryland air regulations) is intended, again in part, to complete the removal of the 

applicability of TM 90-01 to portland cement plants. (It is also intended to consolidate all the 

requirements for portland cement manufacturing plants into one chapter.) Lehigh believes that the 

flexibility it requests for the transition from COMs to particulate CEMS through these comments 

should also be incorporated in the new Chapter 30. Lehigh intends to provide a similar comment on 

the new chapter when it is published in the Maryland Register. The comment will requests the 

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addition of a provision in Regulation .04, Visible Emissions, which continns that particulate CEMS 

can be substituted for COMs to monitor compliance with the Maryland visibility standard. 

Please do not hesitate to contact me at 410-267-5900 or thenderson@richlaw.com with any 

questions. 

Very truly yours, 

TRH/wmf 

cc: K. Deery, Lehigh Portland Cement Company LLC 

K. Martin, Lehigh Portland Cement Company LLC 
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Comparison to Federal Standuds 

There is a corresponding federal sUindard to this proposed action, 

but tile proposed action is not more restrictive or stringent. 

Estimate ofEeonomk: lmpRet 

The proposed action has no economic impact. 

Economic lmput on Small Businessa 

Tlte proposed action has minimal or no economic impact on small 

businesses. 

Impact on Individuals with Disabilities 

The proposed action has no impact on individuals with disabilities. 

Opportunity for Public Comment 

The Department of the Environment will hold a public hearing on 

tile proposed action on February IS, 201 l, at 10 a.m. at the 

Department of the Environment, 1800 Wa.slungton Doulevard, lsi 

Floor Conference Rooms, Baltimore, Maryland 21230-1720. 

Interested persons are invited to attend and express their views. 

Comments may be sent to Deborah Rabin, Regulations Coordinator, 

Air ond Radiation Management Admmistration, DepBI'tment or the 

Env•ronl'llCilt, 1800 Washington Boulevard, Suite 730, Baltimore, 

Maryland 21230· 1720, or emailed to drabin@mde.state.md.us. 

Comments must be received not later dtan february 16, 20 I 1, or be 

submitted at the hearing. For more infonnation, call Deborah R.1bin 

at (410) 537-3240. 

Copies of the proposed action and supporting documents are 

available for review at the following locations: Tlte Air and Radiation 

Management Administration; regional offices of the Department in 

Cumberland and Salisbury; all local air quality control offices; and 

local health departments in those counties not having separate air 

quahty control offices. 

Anyone needing !ipC:Cinl accommodations 01 the: pubHc hearing 

~houkl COIUIC\ IM lll:l*'tlllent'~> Fair Practi"s Oi~ at (410) 537-

396-l. 'I"I'Y users mn)' contact the l>cpurtmc:nt through tlu: Maryland 

Rduy Scn·• -c ot 1·800·73S-22S8. 

26.11.01 General Administrative Provisions 

Autl10rhy: Environment ArtiCle, §§1-101, 1-404, 2·101-2- 103, 2· 301-2· 

303, I O-t02, •nd 10-103, Annotated Code ofMaryl1111d 

( .IO'l.'onllnuous Opacity Monitoring Requirements. 

\..:_. A. Applicability and E"ceptions. 

(I) The provisions of this regulation apply to: 

(o)-(d) (text unchanged) 

(e) A nlunicipal waste combustor with a burning capacity 

!greater than I of35 tons or greater pet day. 

(2)-(4) (text unchanged) 

B. (text unchanged) 

C. Cc11ilication ond Quality Assurance Procedures. 

(I)-(4) (text unchanged) 

(S) !fuel] The owner or operator of fuel-burning equipment 

j$ubject to the COM requirements in CO MAR 26.11.091 required to 

install and operate a COM shall meet the quality assurance 

procedures contained in !Technical Memorandum 90-01 "Continuous 

Emission Monitoring (CEM) Policies and Proced\II'CS," Part II 

Quality Assurance Requirements for Continuous Opacity Monitoring 

Systc:msJ COMAR 26.11.31. 

D. - f (text unchanged) 

.11 Continuous Emission Monitoring Reqwlrrment.t. 

A. Applicability and ElCemptions. 

(I) The provisions of this regulation apply to: 

(a) (telCt unchanged) 

lOS 

(b) Municipal waste combustors with a bum'ng capacity 

!greater than) of35 tons or grtattr per day; 

(c) - (d) (text urK:hanged) 

(2) (text unchanged) 

B. General Requirements for CEMs. 

(I) - (2) (tel(t unchanged) 

(3) The owner or operator of: 

(a) A municipal waste combustor (MWC) shall install Ia 

CI::M in accordance: with the requirements in COMAR 26.11.08.07 or 

26.1 1.08.08, as applic•hleJ CF.Ms lo measure and rrcord SO,, NO,. 

carbon monoxide emiss•ions and either COz or OX)Igen; 

(b) A Kraft pulp mill shall install a CEM to measure and 

record (process total reduced sulfur in accordance with COMAR 

26.11.14.05) SOJ andflow; and 

(c) A fluidized bed combustor or any size shall install CEMs 

to measure ortd rtcord sulfur dioxide, nitrogen oxide and c: th~r 

oxygen or carbon dioxide. __.. 

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(I) CEM System Doltlfllime Reporling Requiremenu 

(a) All CEM system downtime that lasu or i1 expected to 

last more than 24 hours shall be reported to the Department by 

telephone before 10 a.m. of the first regular brumess day following 

the brealcdown. 

(b) The system breulcdown report required by §E(I)(a) of 

this regulation shall include the reason, if known, f or the bna/cdown 

and the estimated period of time that the CEM will be down, The 

owner or operator of the CEM :shall notify tht Dtporlment l1y 

telephone when an out-of-service CEM is baclc in operation and 

producing data that has mel performuna! specifications for accumcy, 

reliability, and durability of acceptable monitoring systems, as 

vided in c:{)MA R 26.. 11-8-and .is JJ!!!Jiucillg tUlia. --.. ./ 

(2) GEM Dtrta Hrporiing Hftltlirtmtrlt:t. '-_........,.. "" ( 

(11} A CF\1 thalf mltofiiCitlettlly n:duce ttl/ de/Ill w 6.muurtt· 

hlad ll'l'11184:.r J.'alcuhlll•d frau' J6 or muf'l! tqrml(l spc1,·ccJ tl•tW 

f'Hl/111~ --------- I 

--ri{Afl test rc.tllfts lfiil/~rrr!d1rrrrforn"iiitltpptovecl by-"' 

the Deportment. 

(c) Certification testing shall be repeated vhen the 

Deparlnrefll deter111ines that the CEM data may not meet 

perfof'lliQnce specifications because of camponent replacement or 

other conditions that affect the quality of generated data. 

(d} A quarterly summary report shall be s11bm11led to the 

Department nol lattr than 30 days foflowing each calendar quarter. 

The report shall be 1n a format approvtd by the Oeportment, and 

shall include the following: 

(I) The caun, time periods, and magnitude of all 

emission:s which exceed the applicable emission standards, 

(ii) The source downtime including the trine and date of 

the beginning and end of each downtime period and whether the 

!ource downtrme was planned or unplanned; 

(iii) The time periods and cause of all CEM downtime 

inr:llidmg recards of any repairs, adjustments. or maintenance that 

may affect the ability of the CEM Ia meet performance specrficutions 

of em•ss1on data; 

(iv) Quarterly totals of excess emisstons, mslallaflon 

dow11time, and CEM dowfllime during the calendar quarter; 

(v) Quarterly qw lity assurance activlltes; 

(vi) Daily ca/ibrallon actnllltes that include re ~ 

values, actual valueJ.:, absolute or percent of span diflerencn , and 

drift suuu.s: and 

(vti} Other information requtred by the Deportment that 

is determined to ht! necessary ro el!aluole the data, to ensurt! that 

MARYLAND REGISTER. VOLUME 38, ISSUE Z, Jo'IUDA Y, JANUAJU' 14,2011 
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AIR AND RADIATION MANAGEMENT ADMINISTRATION 

PUBUC HEARING ON REGULATIONSIAIIENDIIENTS 

Date: February 15, 2011 

Signature Street Addresa City/Statal 

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