SIP SUBMITTAL COMPLETENESS CRITERIA CHECKLIST (in accordance with 40 CFR Part51 -App. V) SIP Submitted by: Maryland Department ofthe Environment Date Submitted: April 22, 2009 Subject: SIP# 10-06 Repeal of .15C(4) and Amendments to Regulation .15A and .15C under COMAR 26.11.19, Volatile Organic Compounds from Specific Processes. Completeness Review Completed by: Christopher Cripps Date Completed: OctOber 15, 2010 Administrative Materials ACCEPTABLE EPA REQUIREMENT STATE SUBMITTAL 1(X) 1.A formal letter of submittal from the Governor orhis designee, 1. Letter dated April 22, 2009 from Shari T. Wilson, Secretary, X equesting EPA approval ofthe plan or revision thereof. Maryland Department ofthe Environment to Shawn Garvin, Regional Administrator. 2. Evidence that the State has adopted the plan inthe State code or2. The State has submitted evidence that the regulations were X odyof regulations; or issued the permit, order, consent agreement adopted and approved in final form on March 21, 2010, with an nfinal form. That evidence shall include the date of adoption or ffective date of April 19, 2010 (Volume 37, Issue8page 623of final issuance as well asthe effective date ofthe plan, if different :he Maryland Register, April 9, 2010). fiom the adoption/issuance date. 3. Evidence that the State has the necessary legal authority under 3.The regulations were issued pursuant to Maryland X State lawto adopt and implement the plan. Environment Article, §1-101, 1-404, 2-101 — 2-103, 2-301——2- 303, 10-102, and 10-103, Annotated Code of Maryland; Ch.23, &cts of 2006.EPA REQUIREMENT STATE SUBMITTAL (X) . A copy of actual regulation, or document submitted for approval 1..A copy ofthe proposed rule was published inthe Maryland rnd incorporation by reference into the plan, including indication of Register on December 18, 2009 (Volume 36, Issue 26,pp. 2073- X he changes made tothe existing approved plan, where applicable. 2074), and the final rule was published inthe Maryland Register rhe submittal shall beacopy ofthe official State )fl April 9, 2010 with an effective date of April 19, 2010 ‘egulationldocument signed, stamped, dated bythe appropriate State (Volume 37, Issue8page 623ofthe Maryland Register, April 9, fficial indicating thatitis fully enforceable bythe State. The 2010). effective date ofthe regulationldocument shall, whenever possible, e indicated inthe document itself. 5. Evidence that the State followed allofthe procedural 5. Cover letter transmitting the SIP revision dated April 22, X equirements ofthe State’s laws and constitution in conducting and 2009. Copies and certification of public hearing notices.

ompleting the adoptionlissuance ofthe plan. 6. Evidence that public notice was given ofthe proposed change 6. Notice of public hearing and public comment period was X consistent with procedures approved by EPA, including the date of ,ublished inThe Washington Post and MDE’s web siteon )ublication of such notice. December 17, 2009 andinThe Baltimore Sun and the The ‘rederick News-Post on December 18, 2009, and copies of these iotices were provided. A hearing transcript is provided. 7. Certification that public hearings were held in accordance with 7. Original Transcript of Public Hearing was provided inthe X he information provided inthe public notice and the State’s laws pril 22, 2009 submittal. and constitution, if applicable.

8. Compilation of public comments and the State’s response thereto. 8.No public comments were received. XTechnical Materials 5. Modeling information required to support the proposed revision, including input data, output data, models used, ambient monitoring 1ata used, meteorological data used, justification foruseof offsite 1ata (where used), modes of models used, assumptions, and other information relevant tothe determination of adequacy ofthe nodeling analysis. EPA REQUIREMENT STATE SUBMITTAL 1. Identification ofall regulated pollutants affected bythe plan. 1.The submittal identifies VOCs, which are precursors of8- X iour ozone. 2. Identification ofthe locations of affected sources including the 2. State of Maryland. EPA attainment/nonattainment designation ofthe locations and the X status ofthe attainment plan forthe affected area(s). 3. Quantification ofthe changes inplan allowable emissions from the3. The plan establishes requirements to limit volatile organic X affected sources; estimates of changes in current actual emissions compounds (VOCs) from the application of adhesives applied from affected sources or, where appropriate, quantification of o “specialty electronic systems and subsystems for defense and changes in actual emissions from affected sources through iomeland security.” calculations ofthe differences between certain baseline levels and allowable emissions anticipated asa result ofthe revision. .The State’s demonstration that the national ambient air quality 1..This revision would add VOC control requirements for X standards, prevention of significant deterioration increments, adhesives applied to “specialty electronic systems and easonable further progress demonstration, and visibility, as subsystems for defense and homeland security” tothe SIP. applicable, are protected ifthe planis approved and implemented. . . lie revision would repeal section C(4) because itwas replaced

)y COMAR 26.11.35 “Control of Emissions of Volatile Organic Compounds from Adhesives and Sealants” (submitted as revision tothe Maryland SIPon April 18, 2008 andbya revised section C(4) to address a remaining source exempted by

inder COMAR 26.1 1.35.01C2©.. 5.Not applicable. No modeling demonstration was required to X support the required revision. No additional modeling beyond

JAM attainment modeling is needed.EPA REQUIREMENT STATE SUBMITTAL 6. Evidence, where necessary, that emission limitations are based on6.The plan establishes adaily cap (averaged monthly) onthe X continuous emission reduction technology, emissions from VOCs emitted bythe application of adhesives applied to “specialty electronic systems and subsystems for lefense and homeland security.” 7. Evidence that the plan contains emission limitations, work practice 7.The plan adds requirements to limit VOCs from the X standards and recordkeeping/reporting requirements, where application of adhesives applied to “specialty electronic lecessary, to ensure emission levels, systems and subsystems for defense and homeland security”and specifies the records tobe kept and the averaging times. 8. Compliance/enforcement strategies, including how compliance 8.The plan adds requirements to limit VOCs from specifies the X villbe determined in practice. ‘ecords tobe keep and the averaging times.” And specifies the ‘ecords tobe keep and the averaging times. 9. Special economic and technological justifications required byany9.No special justifications are required. X applicable EPA policies. (Ifa policy isnot appropriate, explain why.) 10.A Section 107 request must be accompanied bya maintenance 10. Not applicable because thisisnota section 107 request. X )lan demonstrating maintenance tothe relevant NAAQS forat least

10 years after redesignation.