Revision to 

Georgia's State Implementation Plan 

To Incorporate The Requirements of 

Clean Air Act Section 182(b)(2)(A) 

For the Grou 111 Control Techniques Guidelines 

State of Georgia 

Department of Natural Resources 

Environmental Protection Division 

Air Protection Branch 
TABLE OP CONTENTS 

1.0 REGULATORY BACICGROUND .................................................................................. 1 

2.0 PAPER. FILM AND FOIL COATINGS ........................................................................ 3 

3.0 METAL FURNITURE COATINGS ..................................... ........................................ 7 

4.0 LARGE APPLIANCE COATINGS .............................................................................. 11 
EXECUTIVE SUMMARY 

Clean Air Act (CAA) Section 182(b)(2)(A) provides that for certain nonattainment areas, 

States must revise their State Implementation Plans (SIPS) to include reasonably available 

control technology (RACT) for each category of volatile organic compound (VOC) 

sources covered by a control techniques guidelines (CTG) document issued between 

November 15, 1990, and the date of attainment. In addition, Section 182(b)(2) requires 

that a CTG issued between November 15, 1990, and the date of attainment include the 

date by which States subject to Section 182(b) must submit SIP revisions in response to 

the CTG. 

EPA addressed source categories of VOC emissions in accordance with CAA Section 

183(e) on October 9, 2007, by amending 40 CFR Part 59 Subpart A Section 59.1 for 

Consumer and Commercial Products, Group 111 [72 FR 572151: Control Techniques 

Guidelines in Lieu of Regulations for Paper, Film, and Foil Coatings; Metal Furniture 

Coatings; and Large Appliance Coatings. 

States with moderate or above ozone nonattainment areas as of that date were required to 

submit SIP revisions to EPA addressing these requirements on or before October 7,2009. 

Source categories covered under the "Group III" heading are: 

Paper, film and foil coatings; 

Metal furniture coatings; and 

Large appliance coatings. 

Georgia EPD uudertoolc the task of reviewing existing VOC control measures for 

indust~y groups covered by the federal 2007 Group I11 CTGs using the Group 111 CTGs 

and EPA's Blue Book.' The location of the industry groups for this study are those 

located in the current 20-county Atlanta 8-hour ozone moderate non-attainment area 

consisting of Banow, Bartow, Carroll, Cherokee, Clayton, Cobb, Coweta, DeICalb, 

Douglas, Fayette, Forsyth, Fnlton, Gwinnett, Hall, Henry, Newton, Paulding, Roclcdale, 

Spalding and Walton counties. Each CTG contains applicability, emission limitation, 

compliance methods, and monitoring guidelines. 

Issues Relating to VOC Regulation Cutooints, Deficiencies, and Deviations-Clarification to Appendix D 

of November 24. 1987 Federal Register, May 25, 1988, EPA OzoneiCarbon Monoxide Program Branch, 

Air Quality Management Division, Office of Air Quality,Planning and Standards. 

1 
Georgia has adopted the Gsoup I11 CTGs as follows: 

CTG Category 

Paper, Film and Foil 

Coatings 

Metal Furniture 

Coatings 

Large Appliance 

Coatings 

391-3-1-.02(2)(~) 

"VOC Emissions from 

391-3-1-.02(2)(y) 1/25/2012 

"VOC Emissions from 

Changes to the Georgia 

Rules 

Amended 

Metal Furniture Coating" 1 

Amended 

Adoption 

Date 

1/25/2012 

391-3-1-.02(2)(~) 1/25/2012 

"VOC Emissions from 

Compliance 

Date 

1/1/2015 

Georgia is submitting this Group I11 CTG SIP revision, in accordance with CAA Section 

182@)(2)(A), that addresses the changes to existing VOC control measures in Georgia 

Chapter 391-3-1. 

It is important to note that the State of Georgia did not rely on the reduction of 

VOCs as aart of its control stratew for the attainment of the National Ambient Air & -" 

Quality Standards (NAAQS) for 8-hour ozone. Anthropogenic VOCs are 

overwhelmed by biogenic VOCs in the Southeast, resulting in NOx limited ozone 

formation as detailed in the Atlanta 8-hour ozone ~ttainment Demonstration 

submitted to EPA on October 21,2009. 
Georgia Group 111 CTG SIP Revision 

1.0 REGULATORY BACKGROUND 

1.1 Atlanta Ozone Nonattainment Area 

Under the former l-hour ozone National Ambient Air Quality Standard (NAAQS), the 

previous 13-county Atlanta ozone nonattainment area, consisting of Cherokee, Clayton, 

Cobb, Coweta, DeKalb, Douglas, Fayette, Forsyth, Fulton, Gwinnett, Henry, Paulding 

and Rockdale Counties, was classified as a severe nonattainment area. As a part of the 

nonattainment designation, Georgia EPD implemented control measures for ozone 

precursors VOC and NOx that fulfilled the purposes of Section 182(b)(2) for the 1-hour 

ozone NAAQS. These control measure provisions are still in place as part of the 

approved 1 -hour ozone metro Atlanta maintenance plan. 

On April 30, 2004 the Atlanta nonattainment area was initially designated as a marginal 

nonattainment area under the 1997 8-hour ozone NAAQS and expanded from the original 

13-county area to a 20-county area by adding Barrow, Bartow, Carroll, Hall, Newton, 

Spalding and Walton counties. Atlanta was reclassified as a moderate nonattainment area 

on March 6,2008. 

As presented in the Atlanta 8-hour Ozone Attainment Demonstration submitted to EPA 

on October 21, 2009, Georgia EPD has demonstrated that the Atlanta Nonattainment area 

does not rely on VOCs to meet attainment for ozone and is considered a NOx-limited 

area due to overwhelming naturally occurring biogenic VOCs. 

The analyses of ozone, NO, and NOx data using the ozone M.A.P.P.E.R. program 

showed that ozone formation in Atlanta is generally transitional to NOx-limited, but 

when the results were binned according to the daily maximum 8-hour ozone, ozone 

formation was strongly NOx-limited on days of elevated ozone. An analysis of 

weekendlweeliday differences in ozone concentration also indicates a generally NOxlimited regime, with ozone formation becoming more NOx-limited in recent years 

compared to the late 1990s. 

These findings are generally in agreement with several studies of the trends and limiting 

factors for ozone formation in Atlanta. Pun et al. (2003)' investigated the weekly 

patterns of ozone in Atlanta and found elevated midweek concentrations compared to 

weekends, with stronger weekly patterns in later years (1995-1999 compared to 1986- 

1990), concluding that the availability of NOx drives the weekly ozone cycle in Atlanta. 

Analyzing various aircraft measurements, Sillman et al. (1997)~ conclude that Atlanta 

ozone is mostly NOx-limited, using various indicator ratios. 

2 Pun, B. K., C. Seigneul; and W. White (2003). Day-of-week behavior of atmospheric ozone in three U.S 

cities. J. Air & Waste Management Assoc. 53,789-801. 3 Sillman, S., D. He, C. Cardelinn, and R. E. Imhoff (1997). The use of photochemical indicators to 

evaluate ozone-NOx-hydrocarbon sensitivity: Case studies from Atlanta, New York, and Los Angeles. J. 

Air & Waste Management Assoc., 47,1030-1040. 
Georgia Group 111 CTG SIP Revision 

1.2 Clean Air Act Section 182(b)(2) Requirements 

Section 182(b)(2) of the Clean Air Act (CAA) requires that a federal Control Technique 

Guideline (CTG) issued between November 15, 1990, and the date of attainment include 

the date by which States subject to Section 182(b) must submit SIP revisions in response 

to the CTG to include reasonably available control technology (RACT) for each category 

of volatile organic compound (VOC) sources covered by a CTG. 

RACT is defined as the lowest emissions limitation that a particular source is capable of 

meeting by the application of control technology that is reasonably available considering 

technological and economical feasibility (44 FR 53762; September 17, 1979). 

Documents useful in establishing RACT include Control Techniques Guidelines (CTGs), 

Alternative Control Technique guidance (ACT), Maximum Achievable Control 

Technology (MACT) standards, New Source Performance Standards (NSPS), and Best 

Available Control Technology (BACT) determinations. RACT requirements are 

included in the CAA to assure that significant source categories at major sources of ozone 

precursor emissions are controlled to a "reasonable" extent, but not necessarily to BACT 

levels expected of new major sources or major modifications to existing major sources or 

to MACT required for major sources of hazardous air pollutants. 

EPA addressed the Group 111 source categories with promulgation of a "Notice of Final 

Determination and Availability of Final Control Techniques Guidelines" October 9,2007 

[72 FR 572151. States with ozone nonattainment areas classified as moderate or above as 

of that date were required to submit SIP revisions to EPA addressing these requirements 

on or before October 7, 2009. Source categories covered under the "Group III" heading 

are: 

Paper, film and foil coatings; 

Metal furniture coatings; and 

* Large appliance coatings. 

1.3 Conclusion 

Georgia EPD undertook the task of reviewing existing VOC control measures for 

industry groups covered by the federal 2007 Group 111 CTGs. This SIP revision contains 

a chapter for each Group 111 CTG. 
Georgia Group I11 CTG SIP Revision 

2.0 PAPER, FILM AND FOIL COATINGS 

2.1 Regulatory Background - Federal 

Paper, film and foil coating refers to a coating process that applies a continuous layer of 

coating material across essentially the entire width or any portion of a web substrate (web 

coating), in order to provide a covering, finish, or functional or protective layer to a 

substsate; to saturate a substrate for lamination; or to provide adhesion between two 

substrates for lamination. 

There have been three federal actions that affect paper, film, and foil, coating operations 

prior to 2007. In May 1977, EPA issued a CTG document (1977 CTG) for the paper, 

film, and foil coating industries? Then, in October of 1983, EPA promulgated a national 

new source performance standard for pressure sensitive tape and label surface coating 

operations, 40 CFR Part 60 Subpart RR - Standards of Perfomance (NSPS) for 

Pressure Sensitive Tape and Label Surface Coating Operations which is included in the 

paper, film and foil coating sowce category. After this, in December of 2002, EPA 

promulgated a national emission standard for web coating industries, 40 CFR Part 63 

Subpart JJJJ -Nntional Emission Standards for Hazardous Air Pollutants (NESHAP): 

Paper and Other Web Coating. 

2.2 Regulatory Background - State 

Georgia EPD implemented Georgia Rule 391-3-1-.02(2)(w) "VOC Emissions from Paper 

Coating" [a.l<.a. Georgia Rule (w)] to fillfill the VOC RACT requirements for the 1-hour 

ozone NAAQS. Georgia Rule (w) was based on the 1977 federal CTG. This CTG 

addressed surface coating for many different industry categories in addition to paper 

coating. 

2.3 Does the Existing Georgia l-hour Ozone RACT fulfill the %hour Ozone 

RACT for this Industry Sector? 

In September 2007, EPA issued an updated CTG (2007 CTG) document for controlling 

VOC emissions from paper, film and foil coating operations. The following tables 

compare the recommendations under the 2007 CTG and the existing state lule used to 

regulate the category. 

4~uideline Series. Control of Volatile Organic Emissions kom Existing Stationary Sources -Volume IL 

Surface Coating of Cans, Coils, Paper, Fabrics, Automobiles, and Light-Duty Trucks. Publication No. 

EPA-45012-77-008. U.S. EPA, May 1977. 
Georgia Group 111 CTG SIP Revision 

Applicabilitv: Table 2.3.1 specifies the existing VOC emission applicability thresholds 

for paper, film and foil coating: 

-- 

Table 2.. 

Atlanta 

Metro 

Area of 

Concern 

13- 

County 

Note 15 11 

VOC Emission, 

Georgia Rule (w 

Applicability 

Threshold 

voc UPY) 

Actual: 15 Ibslda 

'TE: 100 

xldav of actual emissions before 

cleanit 

EPA r 

icability Threshold 

2007 CTG 

Recommended 

Emission 

Threshold* 

Actual: 15 lbslday 

before controls f& 

work practice 

standards 

Potential: 25 tpy 

for individual 

lines for controls 

Actual: 15 lbslday 

before controls for 

work practice 

standards 

Potential: 25 tpy 

for individual 

lines for controls 

-Paper, Film, and 

EPA Blue Book 

Recommendations 

PTE: 1Otpy 

Actoal: 15 lbslday 

PTE: 1Otpy 

Actual: 15 lbslday 

ecornmends control options 

y threshold for the rule an 

fountain solution standar 

id l 

ds. 

Applicability Threshold 

voc 

individual linesfor 

controls, individual lines 

below 25 tpy subject to 

original Rule (w) limits 

controls for work practice 

standards 

Potential: 25 tpv for 

Actual: 15 lbslday before 

controls for work practice 

standards 

Potential: 25 tpy for 

individual lines for 

controls, individual lines 

below 25 tpy subject to 

original Rule (w) limits at 

&lities above ioo tpy 

.esults in a facility being subject to 

At the higher potential emission 

"Appendix C -Regulatory Guidance" of the 1977 CTG recommends a small source cutoff 

limit, but does not specify what that limit should be, however in EPA's Blue Book, paper 

coating was listed as a source category for the recommended exemption level of 15 

pounds per day of actual emissions. There are nine known affected owners/operators 

subject to Georgia Rule (w). 

Emission Standards for Paper, Film, and Foil Coating: For facilities with actual 

emissions greater than 15 pounds per day, EPA recommends that the facility implement 

work practice standards for cleaning that include storing all VOC-containing cleaning 

materials and used shop towels in closed containers; ensuring that storage containers used 

for these materials are kept closed at all times except when accessing the containers; 

minimizing spills of the VOC-containing cleaning materials; conveying these materials 

from one location to another in closed containers or pipes; and minimizing VOC 

emissions from the cleaning processes associated with application, storage, mixing, and 

conveying equipment. This should be done by ensuring that equipment cleaning is 

performed without atomizing the cleaning solvent and all spent solvent is captured in 

closed containers. 

For surface coating lines with a potential to emit (PTE) of 2.5 tons of VOC per year, EPA 

recommends an overall VOC control efficiency of ninety percent. As an alternative to 
Georgia Group 111 CTG SIP Revision 

the ninety percent control efficiency, the use of low-VOC content materials or a 

combination of materials and controls can be used. An overall 90 percent control 

efficiency is greater than the existing control requirements in Georgia Rule (w). 

Table 2.3.2 compares the recommended control strategies of the 2007 federal CTG with 

the existing emission standards in Georgia Rule (w). 

Table 2.3.2 Comparison Of The 2007 Federal CTG VOC Emission Standards for Paper, Film and I 

Foil Coating with~xistin~ Em 

Paper, Film, and Foil Coating 

Category 

Pressure sensitive tape and label 

snrface coating 

Paper, Film and Foil Surface 

Zoating (Not including Pressure 

Sensitive Tape and Label) 

Ion Standards in 

2007 federal 

CTG 

0.2 lhs VOC per 

1h of solids 

applied, or 

0.067 lhs of 

VOC per lhs of 

coating applied 

0.4 lbs VOC per 

Ihs of solids 

applied, or 

0.08 lbs of VOC 

per lhs of coating 

applied 

(equivalent to 

2.06 lbs of VOC 

per gallon of 

:eating applied). 

Existing Georgia Rule (w) 

2.9 lbs per gallon of coating as 

applied 

solids equivalent limit: 

4.79 lhs per gallon of coating 

solids 

2.9 lhs per gallon of coating as 

applied 

solids equivalent limit: 

4.79 lbs per gallon of coating 

solids 

More 

Stringent 

Limitation 

2007 CTG 

2007 CTG 

The CTG states that the general limits 0.4 lb VOC/lb solids applied and 0.08 lb VOCIlb 

coating applied limits are equivalent to 2.06 lb VOC/gallon of coating applied. This is 

more stringent than the Georgia Rule (w) limit of 2.9 Ib VOC per gallon of coating 

applied. Therefore, the general VOC limits of the CTG are more stringent than Georgia 

Rule (w) limits. Since the pressure sensitive tape and label surface coating limits are 

more stringent than the general CTG limits, then the pressure sensitive tape and label 

limits are more stringent than the Georgia Rule (w) limits as well. 

The emission standards of Georgia Rule (w) are applicable. on a facility-wide basis, as 

opposed to a coating line basis. Thus, coating lines with potential VOC emissions below 

25 tons per year will still be subject to the emission standards of Georgia Rule (w) 
Georgia Group I11 CTG SIP Revision 

Com~liance Methods: Facilities subject to the updated Georgia Rule (w) will be able to 

comply with the requirements of the rule by following the work practice standards 

spelled out in the rule. Those facilities with individual coating lines that have a potential 

to emit 25 tons per year or more will have the option of meeting a low VOC content 

coating or installing control equipment with the required control efficiency. Although 

not spelled out in the rule, control equipment can be used to meet the content coating 

emission limits. 

Procedures for Testing and Monitorine: There are no revisions to Georgia EPD's 

PTM. 

Conclusion: Georgia EPD adopted revisions to Georgia Rule (w) for the 20-county 

Atlanta ozone nonattainment area on January 25,2012 with a compliance date of January 

1,2015. 

Prior to January 1, 2015, paper, film, and foil coating facilities, including pressure 

sensitive tape and label coating facilities located in the original 13-county nonattainment 

area whose potential VOC emissions from theses activities are greater than or equal to 15 

pounds per day will be subject to the original requirements of this rule. The original 

requirements will also apply for these types of facilities with potential VOC emissions 

greater than 100 tons per year that are located in the seven additional nonattainment 

counties. 

Beginning on or after January 1, 2015, the rule revisions will apply to paper, film, and 

foil coating facilities, including pressure sensitive tape and label coating facilities within 

the entire 20-county nonattainment area with actual VOC emissions equal to or greater 

than 15 pounds per day before controls; while the original requirements continue to apply 

for these types of facilities located outside of the nonattainment counties with potential 

VOC emissions greater than 100 tons per yeas. 

However, because the metro Atlanta area has attained the 1997 ozone NAAQS without 

these rules in place, if the area is re-designated attainment before Januasy 1, 2015 and 

those counties continue to maintain the standard, the revisions will no longer apply. In 

the event that the 1997 ozone standard is violated in the specified nonattainment counties, 

the revised requirements will only be reinstated if they are determined to be a necessary 

measure to meet the requirements of the maintenance contingency plan. 
Georgia Group I11 CTG SIP Revision 

3.0 METAL FURNITURE COATINGS 

3.1 Regulatory Background - Federal 

Metal furniture coatings refer to coatings on furniture with a metal substrate that serve a 

decorative, protective anNor functional purpose. Coatings protect the metal from 

corrosion by providing resistance to moistuse, heat, and sometimes the outdoor elements. 

There have been three federal actions that affect metal furniture coating operations prior 

to 2007. In May 1977, EPA issued a CTG document (1977 CTG) for the metal furniture 

coating industries.' Then, in October of 1982, EPA promulgated a national new source 

perfo~mance standard for metal fiuniture coatings, 40 CFR Part 60 Subpart EE - 

Standards of Performance (NSPS) for Surface Coating of Metal Furniture. Afker this, in 

May of 2003, EPA promulgated a national emission standard for metal furniture coating 

operations, 40 CFR Part 63 Subpart RRRR - National Emission Standardsfor Hazardous 

Air Pollutants (NESHAP): Skrface Coating of Metal Furniture. 

3.2 Regulatory Background - State 

Georgia EPD implemented Georgia Rule 391-3-1-.02(2)(y) "VOC Emissions from Metal 

Furniture Coating" [a.k.a. Georgia Rule (y)] to fulfill the VOC RACT requirements for 

the l-hour ozone NAAQS. 

3.3 Does the Existing Georgia l-hour Ozone RACT fulfill the %hour Ozone 

RACT for this Industry Sector? 

In September 2007, EPA issued an updated CTG (2007 CTG) document for controlling 

VOC emissions from metal furniture coating operations. The following tables compare 

the recommendations under the 2007 CTG and the existing state rule used to regulate the 

category. 

Applicability: Table 3.3.1 specifies the existing VOC emission applicability thresholds 

for this industry category. 

I* ' .. of Concern o~lmb~litv '"' I Recommended 

~h;eshold " Emission Threshold 

voc @PY) 

13-County Actual: 15 lbslday Actual: 15 lbslday 

before controls 

7-County PTE: 100 Actual: 15 lbslday 

before con@ols 

Actual: 15 lbslday before 

The 1977 CTG does not recommend an applicability limit, but in EPA's Blue Book, 

metal fwnitwe coating was listed as a source category for the recommended exemption 

5 Guideline Series. Control of Volatile Organic Emissions fiom Existing Stationa~y Sources -Volume 111: 

Surface Coating of Metal Furniture. Publication No. EPA-45012-77-032. U.S. EPA, December 1977. 
Georgia Group I11 CTG SIP Revision 

level of 15 pounds per day of actual emissions. There are no known affected 

owners/operators subject to Georgia Rule (y). 

Emission Standards for Metal Furniture Coating: For facilities with actual emissions 

greater than 15 pounds per day, EPA recommends that the facility implement work 

practice standards for both coating-related activities and cleaning materials. These work 

practice standards include storing all VOC-containing materials and used shop towels in 

closed containers; ensuring that storage containers used for these materials are kept 

closed at all times except when accessing the containers; minimizing spills of the VOCcontaining materials; conveying these materials from one location to another in closed 

containers or pipes; and minimizing VOC emissions from all processes (coating and 

cleaning) associated with application, storage, mixing, and conveying equipment. The 

2007 CTG also recommends that facilities use application techniques with a transfer 

efficiency equivalent to high volume low pressure (HVLP) or electrostatic spray 

application methods including flow/cuitain applications, roll coating, dip coat 

applications, electrodeposition, brush coating, airless spraying, or air-assisted airless 

spray. 

In addition to work practice standards for both coating and cleaning processes and the 

coating equipment standards, the 2007 CTG recommends the use of low-VOC content 

materials. Table 3.3.2 compares the emission limits recommended in the 2007 CTG to 

those in existing Georgia Rule (y) in units of pounds-per-gallon of coating. Table 3.3.3 

compares the emission limits recommended in the 2007 CTG to those in existing Georgia 

Rule (y) in units of pounds per gallon of coating solids. Georgia EPD is adopting the 

more stringent VOC emission limit for each of the coating types. 
Georgia Group I11 CTG SIP Revision 

Table 3.3.3 Comparison Of The 2007 Federal CTG VOC Emission Standards for Metal Furniture Coatings 

With Existing Emission Standards In Georgia Rule (y) In Lbs Per Gallon of Coating Solids. 

Coating Type Baked I Air-Dried 

2007 CTG I Georgia Rule 1 More 1 2007 CTG I Georgia I More Stringent? 

*Note: The VOC content limit has an equivalent solids based limit, but the 2007 CTG and existing Georgia 

Rule (y) appear slightly different because of sounding in CTG calculations. 

As an alternative to the use of low-VOC content materials, facilities have the option of 

add-on control with 90 percent overall control efficiency or a combination of materials 

and controls can be used to meet the VOC content limit required by the CTG. 
Georgia Group I11 CTG SIP Revision 

Compliance Methods: Facilities subject to the updated Georgia Rule (y) will be able to 

comply with the requirements of the rule by following the work practice standards 

spelled out in the rule. Facilities will have the option of meeting the VOC content limits 

for coatings or installing control equipment with the required control efficiency. 

Although not spelled out in the rule, control equipment can be used to meet the content 

coating emission limits. 

Procedures for Testing and Monitoring: There are no revisions to Georgia EPD's 

PTM. 

Conclusion: Georgia EPD adopted revisions to Rule Georgia Rule (y) for the 20-county 

Atlanta ozone nonattainment area on January 25, 2012, with a compliance date of 

Janumy 1,2015. 

Prior to January 1, 2015, metal furniture coating facilities located in the original 13- 

county nonattainment area whose potential VOC emissions from these activities are 

greater than or equal to 15 pounds per day will be subject to the original requirements of 

this rule. The original requirements will also apply for these types of facilities with 

potential VOC emissions greater than 100 tons per year that are located in the seven 

additional nonattainment counties. 

Beginning January 1, 2015, the rule revisions will apply to metal furniture coating 

facilities withm the entire 20-county nonattainment area with actual VOC emissions 

equal to or greater than 15 pounds per day before controls, while the original 

requirements continue to apply for these types of facilities located outside of the 

nonattainment counties with potential VOC emissions greater than 100 tons per year. 

However, because the metro Atlanta area has attained the 1997 ozoneNAAQS without 

these rules in place, if the area is re-designated attainment before January 1,2015 and 

those counties continue to maintain the standard, the revisions will no longer apply. In 

the event that the 1997 ozone standard is violated in the specified nonattainment counties, 

the revised requirements will only be reinstated if they are determined to be a necessary 

measure to meet the requirements of the maintenance contingency plan. 
Georgia Group I11 CTG SIP Revision 

4.0 LARGE APPLIANCE COATINGS 

4.1 Regulatory Background - Federal 

A large appliance past refers to any organic surface coated metal lid, door casing panel or 

other interior or exterior metal part or accessory that is assembled to fosm a large 

appliance product including ranges, ovens, microwave ovens, refrigerators, freezers, 

washers, dryers, dishwashers, water heaters, or trash compactors for household, 

commercial, or recreational use. 

There have been three federal actions that affect large appliance coating operations prior 

to 2007. In December of 1977, EPA issued a CTG document (1977 CTG) for the large 

appliance coating industry.6 Then, in October of 1982, EPA promulgated a national new 

source perfo~mance standard for large appliances, 40 CFR Past 60 Subpart SS - 

Standards of Perfo~mance (NSPS) for Industrial Surface Coating: Large Appliances. 

After this, in July of 2002, )?,PA promulgated a national emission standard, 40 CFR Past 

63 Subpart NNNN - National Emission Standards for Hazardous Air Pollutants 

(NESHAP): Surface Coating of Large Appliances. 

4.2 Regulatory Background - State 

Georgia EPD implemented Georgia Rule 391-3-1-.02(2)(z) "VOC Emissions from Large 

Appliance Surface Coating" [a.k.a. Georgia Rule (z)] to fulfill the VOC RACT 

requirements for the 1-hour ozone NAAQS. 

4.3 Does the Existing Georgia l-hour Ozone RACT fulfill the %hour Ozone 

RACT for this Industry Sector? 

In September 2007, EPA issued an updated CTG (2007 CTG) document for controlling 

VOC emissions from large appliance coating operations. The following tables compare 

the recommendations under the 2007 CTG and the existing state rule used to regulate the 

category. 

6~uideline Series. Control of Volatile Organic Emissions from Existing ~tationa~i~ources -Volume V: 

Surface Coating of Large Appliances. Publication No. EPA-45012-77-034. US. EPA, December 1977. 

I1 
Georgia Group 111 CTG SIP Revision 

Applicabilitv: Tables 4.3.1 specifies the existing VOC emission applicability thresholds 

for industries covered under this CTG: 

The 1977 CTG does not recommend an applicability limit, but in EPA's Blue Book, large 

appliance surface coating was listed as a source category for the recommended exemption 

level of 15 pounds per day of actual emissions. There are no known affected 

ownersloperators subject to Georgia Rule (z). 

Table 4.3.1 VOC Emission Aeplicability Tl~resholds - Large Appliance Surface Coating 

Emission Standards:- For facilities with actual emissions greater than 15 pounds per 

day, EPA recommends that the facility implement work practice standards for both 

coating-related activities and cleaning materials. These work practice standards include 

storing all VOC-containing materials and used shop towels in closed containers; ensuring 

that storage containers used for these materials are kept closed at all times except when 

accessing the containers; minimizing spills of the VOC-containing materials; conveying 

these materials from one location to another in closed containers or pipes; and 

minimizing VOC emissions from all processes (coating and cleaning) associated with 

application, storage, mixing, and conveying equipment. The 2007 CTG also 

recommends that facilities use application techniques with a transfer efficiency 

equivalent to high volume low pressuse (HVLP) or electrostatic spray application 

methods including flowlcu1tain applications, roll coating, dip coat applications, 

electrodeposition, brush coating, airless spraying, or air-assisted airless spray. 

Atlanta Metro Area 

of Concern 

13-County 

7-County 

In addition to work practice standards for both coating and cleaning processes and the 

coating equipment standards, the 2007 CTG recommends the use of low-VOC content 

materials. Table 4.3.2 compares the emission limits recommended in the 2007 CTG to 

those in existing Georgia Rule (z) in units of pounds-per-gallon of coating. Table 4.3.3 

compares the emission limits recommended in the 2007 CTG to those in existing Georgia 

Rule (z) in units of pounds-per-gallon of coating solids. Georgia EPD is adopting the 

more stringent VOC emission limit for each coating type. 

Georgia Rde (2) 

Applicability 

Threshold 

voc (tpy) 

Actual. 15 lbslday 

PTE: 100 

2006 CTG 

Recommended 

Emission Threshold 

Actual: 15 lbslday 

before controls 

Actual: 15 lbslday 

before controls 

Revised Georgia Rule (2) 

Applicability Threshold 

VOC 

Actual: 15 Ibslday befole 

controls 

Actual: 15 Ibslday befo~e 

controls 
Georgia Group I11 CTG SIP Revision 

*Note. The VOC content limit has an eauivalent solids based limit, but the 2007 CTG and existiw Georgi 

Pretreatment 

Coatings 

Solar Absorbent 

Rule (y) appear slightly different because of rounding in CTG calculations 

13 

3.5 

3.0 

2.8 

2.8 

Georgia 

Rule (2) 

Georgia 

Rule (2) 

3.5 

3.5 

2.8 

2.8 

Georgia 

Rule (2) 

Geoigia 

Rule (2) 
Georgia Group 111 CTG SIP Revision 

As an alternative to the use of low-VOC content materials, facilities have the option of 

add-on control with 90 percent overall control efficiency or a combination of materials 

and controls can be used to meet the VOC content limit required by the CTG. 

Corn~liance Methods: ~acilities subject to the updated Georgia Rule (2) will be able to 

comply with the requirements of the rule by following the work practice standards 

spelled out in the rule. Facilities will have the option of meeting the VOC content limits 

for coatings, or installing control equipment with the required control efficiency. 

Although not spelled out in the rule, control equipment can be used to meet the content 

coating emission limits. 

Procedures for Testing and Monitoring: There are no revisions to Georgia EPD's 

PTM. 

Conclusion: EPD adopted revisions to Georgia Rule (z) for the 20-county Atlanta ozone 

nonattainment area on January 25,2012, with a compliance date of January 1,2015. 

Prior to January 1, 2015, large appliance coating facilities located in the original 13- 

county nonattainment area whose potential VOC emissions from theses activities are 

greater than or equal to 15 pounds per day will be subject to the original requirements of 

this rule. The original requirements will also apply for these types of facilities with 

potential VOC emissions greater than 100 tons-per-year that are located in the seven 

additional nonattainment counties. 

Beginning on or after January 1, 2015, the rule revisions will apply to large appliance 

coating facilities within the entire 20-county nonattainment area with actual VOC 

emissions equal to or greater than 15 pounds per day before controls; while the original 

requirements continue to apply for these types of facilities located outside of the 

nonattainment counties with potential VOC emissions greater than 100 tons per year. 

However, because the metro Atlanta area has attained the 1997 ozone NAAQS without 

these rules in place, if the area is re-designated attainment before January 1, 2015 and 

those counties continue to maintain the standard, the revisions will no longer apply. In 

the event that the 1997 ozone standard is violated in the specified nonattainment counties, 

the revised requirements will only be reinstated if they are determined to be a necessary 

measure to meet the requirements of the maintenance contingency plan. 
Georgia Group 111 CTG SIP Revision 

APPENDIX A 

RULE LANGUAGE 
Chapter 391-3-1 Rules for Air Quality Control 

PROPOSED AMENDMENTS TO THE RULES OF THE 

DEPARTMENT OF NATURAL RESOURCES 

ENVIRONMENTAL PROTECTION DIVISION 

RELATING TO AIR QUALITY, CHAPTER 391-3-1 

The Rules of the Department of Natural Resources, Chapter 391-3-1, Air Quality Control are 

hereby amended, added to, repealed in part, revised, as hereinafter explicitly set forth in the 

attached amendments, additions, partial repeals, and revisions for specific rules, or such 

subdivisions thereof as may be indicated. 

[Note: Underlined text is proposed to be added. Lined-through text is proposed for 

deletion.] 

(w) VOC Emissions from Paper Coating. 

1. No person shall cause, let, permit, suffer, or allow the emissions of VOC from paper coating 

to exceed: 

(i) 2.9 pounds per gallon of coating, excluding water, delivered to the coating applicator from a 

paper coating line. This limit shall apply to roll, knife, rotogravure and saturation coater(s) and 

drying oven(s) of paper coating. If any coating delivered to the coating applicator contains more 

than 2.9 pounds VOC per gallon, the solids equivalent limit shall be 4.79 pounds VOC per 

gallon of coating solids delivered to the coating applicator. 

2. The emission limits in wk&h+subparagraph 1. shall be achieved by: 

(i) the application of low solvent coating technology where each and every coating meets the 

limit of 2.9 pounds VOC per gallon of coating, excluding watersub&tw; or 

(ii) the application of low solvent coating technology where the 24-hour weighted average of all 

coatings on a single coating line or operation meets the solids equivalent limit of 4.79 pounds 

VOC per gallon of coating solids-; averaging across 

lines is not allowed; or 

(iii) control equipment, including but not limited to incineration, carbon adsorption and 

condensation, with a capture system approved by the Director, provided that 90 percent of the 

non-methane volatile organic compounds which enter the control equipment are recovered or 

destroyed, and that overall VOC emissions do not exceed the solids equivalent limit of 4.79 

pounds VOC per gallon of coating solids-. 

Page 1 of 14 November 6,201 1 
Chapter 391-3-1 Rules for Air Quality Control 

3. No person shall cause, let, permit, suffer, or allow the emissions of VOC from paper, film and 

foil coating unless: 

Ji) VOC emission reduction equipment with an overall VOC control efficiency is 90 percent for 

each coatina line is installed and operated: or 

(ii) VOC emissions are less than 0.08 pounds per pound of coating for each coating line except 

pressure sensitive tape and label coating; or 

Jii) VOC emissions are less than 0.40 pounds per pound of solids applied for each coating line 

except pressure sensitive tape and label coatinq. 

4. No person shall cause, let, permit, suffer, or allow the emissions of VOC from pressure 

sensitive tape and label coating unless: 

(i) VOC emission reduction equipment with an overall VOC control efficiency is 90 percent for 

each coating line is installed and operated; or 

(ii) VOC emissions areless than 0.067 pounds per pound of coating for each coating line; or 

Jii) VOC emissions are less than 0.20 pounds per pound of solids applied for each coating line. 

5. Each owner or operator of a facility that coats paper, film or foil includina pressure sensitive 

tape and label coating shall comply with the followinq housekeepinq requirements for any 

affected cleaning operation: 

{i) store all VOC-containina cleanina materials and used shop towels in closed containers; 

lii) ensure that storage containers used for VOC-containing cleanina materials are kept closed 

at all times except when depositinn or removinq these materials; 

liii) minimize spills of VOC-containing cleaning materials; 

(iv) convey VOC-containinq cleanina materials from one location to another in closed containers 

or pipes: and 

Page 2 of 14 November 6,201 1 
Chapter 391-3-1 Rules for Air Quality Control 

Iv) minimize VOC emissions from cleaning of application, storaqe, mixinq, and conveying 

equipment by ensurinq that equipment cleaning is performed without atomizinq the cleaning 

solvent and all spent solvent is captured in closed containers. 

6. For the purpose of this subparagraph, the following definitions apply: 

(i) "Knife Coatina" means the application of a coating material to a substrate by means of 

drawinq the substrate beneath a knife that spreads the coating evenly over the full width of the 

substrate; 

{ii) "Paper Coating" means the application of a coatina on paper and pressure sensitive tapes. 

including plastic film and metallic foil, regardless of substrate, in which the coating is distributed 

uniformly across the web; 

[iii) "Roll Coating" means the application of a coatina material to a substrate bv means of hard 

rubber or steel rolls; 

(iv) "Rotoqravure Coatinq" means the application of a coatinq material to a substrate by means 

of a roll coatina technique in which the pattern to be applied is etched on the coating roll. The 

coatinq material is picked up in these recessed areas and is transferred to the substrate. 

7. Applicability. Prior to January 1, 2015, the requirements of this subparaaraph (w) shall apply 

to facilities at which the actual emissions of volatile oraanic compo~mds from paper, film, and foil 

coating, including pressure sensitive tape and label coatinq, equal or exceed 15 pounds per day 

and are located in Cherokee. Clavton. Cobb, Coweta, DeKalb, Douglas, Favette. Forsvth, 

Fulton. Gwinnett. Henrv. Pauldinq, and Rockdale Counties as follows: 

{i) All applicable facilities shall comply with the provisions of subparaqraphs 1.. 2.. and 6. 

8. Applicabilitv. Prior to January 1, 2015, the requirements of this subparagraph (w) shall apply 

to facilities at which the potential emissions of volatile oraanic compounds from paper, film, and 

foil coating, including pressure sensitive tape and label coating, equal or exceed 100 tons per 

year and are located outside the counties of Cherokee. Clavton. Cobb. Coweta, DeKalb, 

Douglas, Favette. Forsvth. Fulton. Gwinnett. Henrv. Pauldinq, and Rockdale Counties as 

follows: 

(i) All applicable facilities shall comply with the provisions of subparaqraphs 1.. 2.. and 6 

9. Applicability. On and after January 1, 2015, the requirements of this Subparaqraph (w) shall 

apply to facilities at which actual emissions of volatile organic compounds from paper, film, and 

foil coating, includinq pressure sensitive tape and label coatina, equal or exceed 15 pounds per 

dav (or 2.7 tons per 12-month rolling period) for facilities located in Barrow, Bartow. Carroll, 

Cherokee, Clavton. Cobb. Coweta. DeKalb, Douglas, Favette, Forsvth. Fulton, Gwinnett, Hall, 

Henrv, Newton, Pauldinq, Rockdale, Spalding, and Walton Counties as follows: 

(i) All applicable facilities shall complv with the provisions of subparaqraphs 5. and 6. 

Page 3 of 14 November 6,201 1 
Chapter 391-3-1 Rules for Air Quality Control 

(ii) lndividual surface coating lines that have potential emissions of volatile orqanic compounds 

from paper, film, and foil coating, including pressure sensitive tape and label coatinq, that equal 

or exceed 25 tons per year shall comply with the provisions of subparaqraphs 3. and 4. 

(iii) lndividual surface coating lines that have potential emissions of volatile orqanic compounds 

from paper. film, and foil coating, includinq pressure sensitive tape and label coatinq, that do not 

equal or exceed 25 tons per vear and are located in Cherokee. Clayton, Cobb, Coweta. DeKalb, 

Douqlas, Fayette. Forsvth, Fulton. Gwinnett. Henrv, Pauldinq, or Rockdale County shall comply 

with the provisions of subparagraphs 1. and 2. 

{iv) lndividual surface coating lines that have potential emissions of volatile organic compounds 

from paper, film, and foil coating. includinq pressure sensitive tape and label coatinq, that do not 

equal or exceed 25 tons per vear but are located at facilities that have potential emissions of 

volatile organic compounds from paper coating that equal or exceed 100 tons per vear and are 

located in Barrow, Bartow, Carroll. Hall, Newton, Spaldinq, or Walton County shall complv with 

the provisions of subparagraphs 1. and 2. 

(v) Any physical or operational changes that are necessary to comply with the provisions 

specified in subparaqraphs 3.. 4.. or 5. are subiect to the compliance schedule specified in 

subparagraph 12. 

10. Applicability. On and after January 1, 2015, the requirements of this subparaqraph (w) shall 

apply to facilities at which potential emissions of volatile organic compounds from paper, film, 

and foil coatinq, including pressure sensitive tape and label coating, equal or exceed 100 tons 

per vear and are located outside of counties of Barrow. Bartow, Carroll. Cherokee. Clayton, 

Cobb. Coweta. DeKalb, Douglas, Fayette. Forsvth, Fulton, Gwinnett. Hall. Henrv. Newton, 

Pauldina. Rockdale, Spalding, and Walton Counties as follows: 

0) All applicable facilities shall complv with the provisions of subparagraphs I., 2.. and 6. 

11. Applicabilitv. The requirements of subparagraphs 9. and 10. will no longer be applicable by 

the compliance deadlines if the counties specifled in those subparagraphs are re-designated to 

attainment for the 1997 National Ambient Air Q~ality Standard for ozone prior to January 1, 

2015 and such counties continue to maintain that Standard thereafter. Instead, the provisions 

of subparaqraphs 7. and 8. will continue to apply on and after January I. 2015. In the event the 

1997 National Ambient Air Quality Standard for ozone is violated in the specified counties, the 

requirements of subparaqraphs 9. and 10. will only be reinstated if the Director determines that 

the measure is necessary to meet the requirements of the contingency plan. 

12. Compliance schedule. 

li) An application for a permit to construct and operate volatile oraanic compound emission 

control systems and/or modifications of process and/or coatings used must be submitted to the 

Division no later than Julv 1, 2014. 

(ii) On-site of construction of emission control systems and/or modification of process or 

coatings must be completed by November 1. 2014. 

Page 4 of 14 November 6.201 1 
Chapter 391-3-1 Rules for Air Quality Control 

(iii) Full compliance with the applicable requirements of subparagraphs 3., 4., and 5. must be 

completed before January I, 2015. 

Rule 391-3-I-.02(2)(y) 'VOC Emissions from Metal Furniture Coating," is being amended to 

read as follows: 

(y) VOC Emissions from Metal Furniture Coating. 

1. No person shall cause, let, permit, suffer, or allow the emissions of VOC from metal furniture 

coating operations to exceed: 

(i) 3.0 pounds per gallon of coating, excluding water, delivered to the coating applicator from 

prime and topcoat or single coat operations. If any coating delivered to the coating applicator 

contains more than 3.0 pounds VOC per gallon, the solids equivalent limit shall be 5.06 pounds 

VOC per gallon of coating solids delivered to the coating applicator. 

(ii) The emission limit in this subparagraph shall apply to the application area(s), flashoff area@) 

and oven(@ of metal furniture coating lines involved in prime and topcoat or single coat 

operations. 

2. The emission limits in s&s&bwsubparaaraph 1. shall be achieved by: 

(i) the application of low solvent coating technology where each and every coating meets the 

limit of 3.0 pounds VOC per gallon of coating, excluding waters&w&w; or 

(ii) the application of low solvent coating technology where the 24-hour or monthly weighted 

average of all coatings on a single coating line or operation meets the solids equivalent limit of 

5.06 pounds VOC-per-gallon of coating solids- 

(averaging across lines is not allowed); or 

(iii) control equipment, including but not limited to incineration, carbon adsorption and 

condensation, with a capture system approved by the Director, provided that 90 percent of the 

nonmethane volatile organic compounds which enter the control equipment are recovered or 

destroyed, and that overall VOC emissions do not exceed the solids equivalent limit of 5.06 

pounds VOC per gallon of coating solids p. 

3. No person shall cause, let, permit, suffer, or allow the emissions of VOC from metal furniture 

coating operations for baked coatings to exceed: 

Page 5 of 14 November 6,201 1 
Chapter 391-3-1 Rules for Air Quality Control 

(i) 2.3 pounds per gallon of coating, excluding water, delivered to the coating applicator from 

general one-component, and general multi-component coatings. If any coatinq delivered to the 

coatinq applicator contains more than 2.3 pounds VOC per aallon, the solids equivalent limit 

shall be 3.3 pounds VOC per qallon of coat'nq solids as applied. 

(ii) 3.0 pounds per gallon of coatina, excludinq water. delivered to the coatinq applicator from 

extreme hiqh qloss, extreme performance, heat resistant, metallic, solar absorbent and 

pretreatment coatings. If any coating delivered to the coatinq applicator contains more than 3.0 

pounds VOC per gallon, the solids equivalent limit shall be 5.06 pounds VOC per gallon of 

coatina solids as applied. 

4. No person shall cause, let, permit, suffer, or allow the emissions of VOC from metal furniture 

coating operations for air-dried coatings to exceed: 

li) 2.3 pounds per gallon of coating, excludinq water, delivered to the coating applicator from 

general one-component coatings. If any coatinq contains more than 2.3 pounds VOC per gallon, 

the solids equivalent limit shall be 3.3 pounds VOC per gallon of coating solids as applied. 

(ii) 2.8 pounds per gallon of coatinq, excludinq water, delivered to the coating applicator from 

general multi-component, and extreme hiqh qloss coathqs. If any coating delivered to the 

coating applicator contains more than 2.8 pounds VOC per qallon, the solids equivalent limit 

shall be 4.5 pounds VOC per gallon of coating solids as applied. 

(ii) 3.0 pounds per gallon of coatina, excludinq water, delivered to the coatinq applicator from 

extreme performance, heat resistant, metallic, solar absorbent and pretreatment coatings. If any 

coatinq delivered to the coatinq applicator contains more than 3.0 pounds VOC per gallon, the 

solids equivalent limit shall be 5.06 pounds VOC per gallon of coatinq solids as applied. 

5. Each owner or operator of a facilitv that coats metal furniture shall ensure that all coating 

application systems utilize one or more of the application techniques stated below: 

(i) Electrostatic spray application; 

lii) High volume low pressure (HVLP) sprayina; 

liii) Flowlcurtain application; 

liv) Roll coatinq; 

(v) Dip coat application including electrodeposition; 

Ivi) Brush coat; 

Ivii) Airless sprav; 

(viii) Air-assisted airless sprav: or 

Page 6 of 14 November 6.201 1 
Chapter 391-3-1 Rules for Air Quality Control 

lix) Other coating application methods that achieve transfer efficiencv equivalent to HVLP or 

electrostatic spray application methods, as determined by the Director. 

6. Each owner or operator of a facilitv that coats metal furniture shall complv with the following 

work practice standards: 

li) store all VOC-containing coatings, thinners, and coatinq-related waste materials in closed 

containers; 

lii) ensure that mixinq and storage containers used for VOC-containinq coatings, thinners, and 

coatinq-related waste materials are kept closed at all times except when depositing or removing 

these materials; 

(iii) minimize spills of VOC-containina coatings, thinners, and coating-related waste materials: 

- and 

(iv) convev VOC-containing coatings, thinners, and coating-related waste materials from one 

location to another in closed containers or pipes. 

7. Each owner or operator of a facilitv that coats metal furniture shall comply with the following 

housekeeping requirements for anv affected cleanina operation: 

(if store all VOC-containing cleaning materials and used shop towels in closed containers; 

(ii) ensure that storage containers used for VOC-containinq cleanina materials are kept closed 

at all times except when depositina or removing these materials; 

(iii) minimize spills of VOC-containinq cleaning materials; 

liv) convev VOC-containing cleaning materials from one location to another in closed containers 

or pipes; and 

lv) minimize VOC emissions from cleaning of application, storage, mixinq, and conveving 

equipment by ensuring that equipment cleaning is performed without atomizing the cleaning 

solvent and all spent solvent is captured in closed containers. 

8. The VOC limits specified in this subparaqraphs 3. and 4. do not applv to the following tvpes of 

metal furniture coatings and/or coating operations: 

li) Touch-up and repair coatings: 

(ii) Stencil coatinqs; 

liii) Safetv-indicating coatings; 

(iv) Solid-film lubricants; 

(v) Electric-insulating and thermal-conducting coatings; and 

Page 7 of 14 November 6,201 1 
Chapter 391-3-1 Rules for Air Quality Control 

(vi) Coatina application utilizing hand-held aerosol cans. 

9. The emission limits in subparagraphs 3. and 4. shall be achieved by: 

(i) the application of low solvent coating technology where each and everv coating meets the 

limit expressed in pounds VOC per gallon of coating, excluding water, stated in subparagraphs 

3. and 4. of this subparagraph; or 

(ii) the application of low solvent coating technologv where the 24-hour weiahted average of all 

coatings on a sinale coatina line or operation meets the solids equivalent limit expressed in 

pounds VOC per aallon of coating solids, stated in subparagraphs 3. and 4. of this 

subparaaraph: averaging across lines is not allowed; or 

liii) control equipment, including but not limited to incineration, carbon adsorption and 

condensation, with'a capture system approved bv the Director, provided that 90 percent of the 

nonmethane volatile organic compounds which enter the control equipment are recovered or 

destroved, and that overall VOC emissions do not exceed the solids equivalent limit, expressed 

in pounds VOC per Gallon of coatina solids stated in subparaaraphs 3. and 4. of this 

subparaqraph. 

10. For the purpose of this subparagraph, the following definitions apply: 

li) "Application Area" means the area where the coating is applied by spravinq, dippinq or flow 

coatinq techniques. 

(ii) "Metal Furniture Coating" means the surface coatinq of anv furniture made of metal or any 

metal part, which will be assembled with other metal wood, fabric, plastic or glass parts to form 

a furniture piece.' 

11. Applicability: Prior to January 1. 2015, the requirements of this subparagraph (v) shall apply 

to facilities at which the actual emissions of volatile oraanic compounds from the use of metal 

furniture coatings equal or exceed 15 pounds per day and are located in Cherokee, Clavton, 

Cobb. Coweta, DeKalb, Doualas, Fayette. Forsyth, Fulton. Gwinnett. Henry, Pauldina, and 

Rockdale Counties as follows: 

(i) All applicable facilities shall comply with the provisions of subbaraqraphs 1 .. 2.. and 10. 

12. Applicabilitv. Prior to January 1, 2015. the requirements of this subparagraph (v) shall 

apply to facilities at which the potential emissions of volatile oraanic compounds from the use of 

metal furniture coatings equal or exceed 100 tons per year and are located outside the counties 

of in Cherokee, Clayton. Cobb. Coweta, DeKalb. Douqlas. Favette. Forsvth. Fulton, Gwinnett, 

Henrv. Pauldina, and Rockdale Counties as follows: 

li) All applicable facilities shall complv with the provisions of subparaaraphs 1.. 2., and 10. 

13. Applicabilitv. On and after January 1. 2015. the requirements of this subparaaraph (v) shall 

apply to facilities at which the actual emissions of volatile organic compounds from the use of 

metal furniture coatings, before controls, equal or exceed 15 pounds per dav (or 2.7 tons per 

12-month rollina period) for facilities located in Barrow, Bartow, Carroll, Cherokee, Clavton, 

Page 8 of 14 November 6,201 1 
Chapter 391-3-1 Rules for Air Quality Control 

Cobb, Coweta, DeKalb, Douglas. Fayette, Forsvth. Fulton, Gwinnett, Hall, Henry, Newton. 

Paulding. Rockdale, Spalding, and Walton Counties as follows: 

li) All applicable facilities shall comply with the provisions of subparagraphs 3., 4.. 5., 6., 7.. 8., 

9.. and 10. 

(ii) Any physical or operational changes that are necessary to comply with the provisions 

specified in subparagraphs 3.. 4.. 5., 6., 7. 8., or 9. are subiect to the compliance schedule 

specified in subparaaraph 16. 

14. On and after January 1, 2015. the requirements of this subparaaraph (v) shall apply to 

facilities at which the potential emissions of volatile orqanic compounds from the use of metal 

furniture coatinqs equal or exceed 100 tons per year and are located outside the counties of 

Barrow. Bartow. Carroll, Cherokee, Clayton, Cobb. Coweta, DeKalb. Douqlas, Fayette. Forsvth. 

Fulton. Gwinnett, Hall. Henry, Newton, Pauldinq. Rockdale, Spaldinq, and Walton as follows: 

(i) All applicable facilities shall comply with the provisions of subparagraphs I., 2..and 10. 

15. Applicabilitv. The requirements of subparagraphs 13. and 14. will no lonqer be applicable 

by the compliance deadlines if the counties specified in those subparaqraphs are re-desiqnated 

to attainment for the 1997 National Ambient Air Quality Standard for ozone prior to January 1. 

2015 and such counties continue to maintain that Standard thereafter. Instead, the provisions 

of subparagraphs 11. and 12. will continue to apply on and after January 1, 2015. In the event 

the 1997 National Ambient Air Quality Standard for ozone is violated in the specified counties, 

the requirements of subparagraphs 13. and 14. will only be reinstated if the Director determines 

that the measure is necessary to meet the requirements of the continaencv plan. 

16. Compliance schedule: 

(i) An application for a permit to construct and operate volatile orqanic compound emission 

control systems and/or modifications of process and/or coatinqs used must be submitted to the 

Division no later than Julv 1, 2014. 

lii) On-site of construction of emission control systems and/or modification of process or 

coatinqs must be completed by November 1, 2014. 

liii) Full compliance with the applicable requirements of subparaqraphs 3., 4.. 5., 6.. 7.. 8., and 

9. must be completed before Januarv I, 2015. 

Rule 391-3-1-.02(2)(z) VOC Emissions from Large Appliance Surface Coating," is being 

amended to read as follows: 

(z) VOC Emissions from Large Appliance Surface Coating. 

1. No person shall cause, let, permit, suffer, or allow the emissions of VOC from the surface 

coating of large appliances to exceed: 

Page 9 of 14 November 6,201 1 
Chapter 391-3-1 Rules for Air Quality Control 

(i) 2.8 pounds per gallon of coating, excluding water, delivered to the coating applicator from 

prime single or topcoat operations. If any coating delivered to the coating applicator contains 

more than 2.8 pounds VOC per gallon, the solids equivalent limit shall be 4.52 pounds VOC per 

gallon of coating solids delivered to the coating applicator; 

(ii) The emission limits in this wkeeh+subparagraph shall apply to the application area(s), 

flashoff area(s) and oven(s) of large appliance coating lines involved in prime, single or topcoat 

coating operations; 

(iii) The emission limit in this wbseskm subparagraph shall not apply to the use of quick drying 

lacquers used for repair of scratches and nicks. 

2. The emission limits in #+&&%&& subparagraph 1. shall be achieved by: 

(i) the application of low solvent coating technology where each and every coating meets the 

limit of 2.8 pounds VOC per gallon of coating, excluding water- 

+=&M&w; or 

(ii) the application of low solvent coating technology where the 24-hour weighted average of all 

coatings on a single coating line or operation meets the solids equivalent limit of 4.52 pounds 

VOC per gallon of coating solids- averaging across 

lines is not allowed; or 

(iii) control equipment, including but not limited to incineration, carbon adsorption and 

condensation, with a capture system approved by the Director, provided that 90 percent of the 

non-methane volatile organic compounds which enter the control equipment are recovered or 

destroyed, and that overall VOC emissions do not exceed the solids equivalent limit of 4.52 

pounds VOC per gallon of coating solids p. 

3. No person shall cause, let, permit, suffer, or allow the emissions of VOC from the surface 

coating of larqe appliances using baked coatinqs to exceed: 

li) 2.3 pounds per qallon of coating, excluding water and exempt compounds, delivered to the 

coating applicator qeneral one component and general multi-component coatinqs. If any coating 

delivered to the coatinq applicator contains more than 2.3 pounds VOC per gallon, the solids 

equivalent limit shall be 3.3 pounds VOC per qallon of coatincl solids delivered to the coating 

applicator; 

Page 10 of 14 November 6,201 1 
Chapter 391-3-1 Rules for Air Quality Control 

(ii) 2.8 pounds per gallon of coatina, excluding water and exempt compounds, delivered to the 

coating applicator from extreme high gloss, extreme performance, heat resistant, metallic, and 

solar absorbent, and pretreatment coatings. If any coating delivered to the coating applicator 

contains more than 2.8 pounds VOC per gallon, the solids equivalent hmit shall be 4.5 pounds 

VOC per qallon of coating solids delivered to the coatinq applicator; 

4. No person shall cause, let, permit, suffer, or allow the emissions of VOC from the surface 

coatinq of large appliances using air-dried coatinqs to exceed: 

(i) 2.3 pounds per gallon of coating, excludin~ water and exempt compounds, delivered to the 

coatina applicator from qeneral one-component coatinqs. If any coatina delivered to the coatinq 

applicator contains more than 2.3 pounds VOC per gallon, the solids equivalent limit shall be 3.3 

pounds VOC per gallon of coatinq solids delivered to the coating applicator; 

(ii) 2.8 pounds per qallon of coating, excluding water and exempt compounds, delivered to the 

coatina applicator from general multi-component, extreme hiah qloss, extreme performance, 

heat resistant, metallic, solar absorbent and pretreatment coatings. If any coating delivered to 

the coatina applicator contains more than 2.8 pounds VOC per gallon, the solids equivalent limit 

shall be 4.5 pounds VOC per gallon of coating solids delivered to the coatinq applicator; 

5. Each owner or operator of a facility that coats large appliances shall ensure that all coating 

application systems utilize one or more of the application techniques stated below: 

li) Electrostatic sprav application; 

(ii) Hiqh volume low pressure (HVLP) sprayinq; 

fiii) Flowlcurtain application; 

(iv) Roll coating; 

(v) Dip coat application including electrodeposition; 

(vi) Brush coat; 

(vii) Airless sprav; 

(viii) Air-assisted airless spray; or 

(ix) Other coating application methods that achieve transfer efficiency equivalent to HVLP or 

electrostatic spray application methods, as determined bv the Director. 

6. Each owner or operator of a facility that coats large appliances shall comply with the followinq 

work practice standards: 

(i) store all VOC-containina coatinas, thinners, and coating-related waste materials in closed 

containers; 

Page 11 of 14 November 6,2011 
Chapter 391-3-1 Rules for Air Quality Control 

(ii) ensure that mixina and storage containers used for VOC-containing coatings, thinners. and 

coating-related waste materials are kept closed at all times except when depositing or removing 

these materials; 

(iii) minimize spills of VOC-containing coatinas, thinners, and coating-related waste materials; 

and 

(iv) vq-related waste materials from one 

location to another in closed containers or pipes. 

7. Each owner or operator of a facility that coats large appliances shall comply with the followinq 

housekeeping requirements for any affected cleaninq operation: 

(i) store all VOC-containina cleaning materials and used shop towels in closed containers; 

(ii) ensure that storage containers used for VOC-containing cleaning materials are kept closed 

at all times except when depositing or removing these materials; 

(iii) minimize spills of VOC-containina cleaning materials: 

Jiv) convey VOC-containing cleaning materials from one location to another in closed containers 

or pipes; and 

(v) minimize VOC emissions from cleanina of application, storaae, mixina, and conveying 

equipment by ensurinq that equipment cleaning is performed without atomizing the cleaninq 

solvent and all spent solvent is captured in closed containers. 

8. The VOC limits specified in subparaqraphs 3. and 4. do not apply to the following types of 

large appliance coatinas and/or coatinq operations: 

(i) Touch-up and repair coatinqs; 

(ii) Stencil coatings; 

(iii) Safety-indicating coatings; 

(iv) Solid-film lubricants; 

(v) Electric-insulating and thermal-conducting coatinas; and 

(vi) Coating application utilizing hand-held aerosol cans. 

9. The emission limits in subparagraphs 3. and 4. shall be achieved by: 

(i) the application of low solvent coatinq technology where each and even/ coating meets the 

limit expressed in pounds VOC per qallon of coating, excluding water, stated in subparagraphs 

3. and 4. of this subparagraph; or 

Page 12 of 14 November 6,201 1 
Chapter 391-3-1 Rules for Air Quality Control 

(ii) the application of low solvent coatinq technology where the 24-hour weiqhted averaqe of all 

coatinqs on a single coating line or operation meets the solids equivalent limit expressed in 

pounds VOC per gallon of coating solids, stated in subparaaraphs 3. and 4. of this 

subparaaraph (averaging across lines is not allowed); or 

(iii) control equipment, including but not limited to incineration, carbon adsorption and 

condensation, with a capture system approved bv the Director, provided that 90 percent of the 

nonmethane volatile organic compounds which enter the control equipment are recovered or 

destroyed, and that overall VOC emissions do not exceed the solids equivalent limit, expressed 

in pounds VOC per qallon of coating sol~ds stated in s~~bparaqraphs 3. and 4. of this 

subparaaraph. 

10. For the purpose of this subparagraph, the following definitions applv: 

{i) "ipplication Area" means the area where the coating is applied by spraying, dipping or flow 

coatinq techniques. 

[ii) "Sinale Coat" means a single film of coatinq applied directly to the metal substrate omittinq 

the primer application. 

(iii) "Large Appliances" means doors, cases, lids, panels and interior support parts of residential 

and commercial washers, drvers, ranqes, refriqerators, freezers, water heaters, dishwashers, 

trash compactors, air conditioners and other similar products. 

11. Applicabilitv. Prior to Januarv 1, 2015, the requirements of this subparaqraph (z) shall 

applv to facilities at which the actual emissions of volatile orqanic compounds from the use of 

larae appliance coatinas equal or exceed 15 pounds per dav and are located in Cherokee. 

Clavton, Cobb, Coweta. DeKalb. Douglas, Favette, Forsvth. Fulton. Gwinnett, Henry. Pauldinq, 

and Rockdale Counties as follows: 

{i) All applicable facilities shall complv with the provisions of subparagraphs I., 2.. and 10. 

12. Applicabilitv. Prior to Januarv 1, 2015, the requirements of this subparagraph (z) shall 

apply to facilities at which the potential emissions of volatile orqanic compounds from the use of 

larae appliance coatings equal or exceed 100 tons per year and are located outside thep 

counties of Cherokee, Clavton, Cobb, Coweta, DeKalb, Douglas. Favette, Forsvth. Fulton, 

Gwinnett. Henrv, Padding, and Rockdale Counties as follows: 

(i) All applicable facilities shall complv with the provisions of subparagraphs 1. 2, and 10 

13. Applicabilitv. On and after January 1, 2015, the requirements of this subparagraph (z) 

apply to facilities at which actual emissions of volatile orqanic compounds from the use of larqe 

appliance coatinqs, before controls, equal or exceed 15 pounds per day (or 2.7 tons per 12- 

month rolling period) for facilities located in Barrow. Bartow. Carroll, Cherokee. Clavton. Cobb, 

Coweta. DeKalb, Douglas, Favette. Forsvth, Fulton, Gwinnett, Hall, Henrv. Newton. Pauldinq, 

Rockdale, Spalding, and Walton Counties as follows: 

(i) All applicable facilities shall comply with the provisions of subparaaraphs 3.. 4.. 5., 6., 7.. 8., 

9. and 10. 

Page 13 of 14 November 6,201 1 
Chapter 391-3-1 Rules for Air Quality Control 

lii) Any physical or operational changes that are necessary to complv with the provisions 

specifled in subparagraphs 3., 4.. 5., 6., 7., 8, or 9. are subiect to the compliance schedule 

specified in subparaqraph 16. 

14. Applicability. On and after January 1, 2015, the requirements of this subparagraph (2) shall 

apply to facilities at which potential emissions of volatile organic compounds from the use of 

large appliance coatings equal or exceed q00 tons per year and are located outside of counties 

of Barrow, Bartow, Carroll. Cherokee, Clayton, Cobb, Coweta, DeKalb, Douglas, Favette, 

Forsvth. Fulton, Gwinnett. Hall, Henry. Newton, Padding, Rockdale, Spaldina, and Walton 

Counties as follows: 

li) All applicable facilities shall complv with the provisions of subparaaraphs 1 ., 2, and 10. 

15. Applicability: The requirements of subparagraphs 13. and 14. will no longer be applicable 

by the compliance deadlines if the counties specified in those subparagraphs are re-designated 

to attainment for the 1997 National Ambient Air Quality Standard for ozone prior to January I, 

2015 and such counties continue to maintain that Standard thereafter. Instead, the provisions 

of subparagraphs 11, and 12. will continue to apply on and after January 1, 2015. In the event 

the 1997 National Ambient Air Quality Standard for ozone is violated in the specified counties. 

the requirements of subparaqraphs 13. and 14. will only be reinstated if the Director determines 

that the measure is necessary to meet the requirements of the contingency plan. 

16. Compliance schedule: All existing facilities subiect to this subparagraph shall complv with 

the following compliance schedule: 

(i) An application for a permit to construct and operate volatile organic compound emission 

control systems and/or modifications of process and/or coatinas used must be submitted to the 

Division no later than July 1. 2014. 

fii) On-site of construction of emission control systems and/or modification of process or 

coatings must be completed by November 1, 2014. 

(iii) Full compliance with the applicable requirements of subparagraphs 3., 4.. 5., 6., 7., 8., and 

9. must be completed before Januarv 1, 2015. 

Authority: O.C.G.A. Section 12-9-1 et seq., as amended. 

Page I4 of I4 November 6.201 1 
Georgia Group 111 CTG SIP Revision 

APPENDIX B 

REVISIONS TO GEORGIA'S PROCEDURES FOR TESTINGAND 

MONITORING SOURCES OFAZR POLLUTANTS 

There are no revisions to Georgia's Procedures for Testing and Monitoring Sources 

of Air Pollutants associated with the Group 111 CTG SIP. 
APPENDIX C 

POTENTIALLY AFFECTED SOURCE LISTING 
Paper, Film and Foil Coating - Georgia Rule (w): 9 Potentially Affected Sources 

AIRS 

04500039 

11300010 

15100022 

08900227 

06300069 

08900143 

08900204 

1 1700039 

13500156 

Facility 

Printpack Inc 

Avery Dennison - Fasson Roll North America 

Toppan Interamerica Inc 

International Paper Company 

Star Packaging Corp 

World Color Printing (USA) Cosp. (dba Worldcolor Atlanta) 

Hood Packaging Corp 

Nitta Belt 

Rohres Corporation 

Metal Furniture Coating - Georgia Rule (y) : 0 Potentially Affected Sources 

Large Appliance -Georgia Rule (z) : 0 Potentially Affected Sources