### Revised VOC Applicability Thresholds for Seven Coun ties

Administrative Materials for SIP submittal dated: J uly 19, 2012

1. A formal letter of submittal from the Governor o r his designee, requesting EPA approval of the plan or revision thereof (hereafter “the plan”).

The cover letter transmitting this proposed plan is the formal letter of submission.

2. Evidence that the State has adopted the plan in the State code or body of regulations; or issued the permit, order, consent a greement (hereafter “document”)

in final form. That evidence shall include the dat e of adoption or final issuance as well as the effective date of the plan if different from the adoption/issuance date.

The following rule revisions are scheduled for adop tion by Georgia’s Board of Natural Resources on August 29, 2012:

• 391-3-1-.02(2)(a)6., “General Provisions, VOC Emiss ion Standards, Exemptions, Area Designations, Compliance Schedules and Compliance

Determinations”

• Rule 391-3-1-.02(2)(kkk), “VOC Emissions from Aeros pace Manufacturing

and Rework Facilities”

3. Evidence that the State has the necessary legal authority under State law to adopt and implement the plan.

The Georgia Air Quality Act, Article 1: Air Quality (O.C.G.A. 12-9, et. seq.) provides the necessary legal authority under State law to adopt and implement the revisions. The Act, in its entirety, is located athttp://www.lexisnexis.com/hottopics/gacode/ under Title 12, Chapter 9, Article 1.

4. A copy of the actual regulation, or document sub mitted for approval and incorporation by reference into the plan, including indication of the changes made to the existing approved plan, where applicable. T he submittal shall be a copy of the official State regulation/ document signed, sta mped, dated by the appropriate State official indicating that it is fully enforcea ble by the State. The effective date of the regulation/document shall, whenever possible , be indicated in the document

itself.

Enclosed is a copy of the proposed regulatory revis ions, dated July 19, 2012, 2012, for approval and incorporation into the State Implementation Plan.

5. Evidence that the State followed all of the proc edural requirements of the State’s laws and Constitution in conducting and completing the adoption/issuance of the plan and compilation of public comments and the Sta te’s response thereto.

This requirement does not apply to plans submitted for parallel processing in accordance with 40 CFR 51 Appendix W, paragraph 2.3 .1(d).

### Revised VOC Applicability Thresholds for Seven Coun ties

6. Evidence that public notice was given of the pro posed change consistent with procedures approved by EPA, including the date of p ublication of such notice and Certification that public hearings(s) were held in accordance with the information provided in the public notice and the State's laws and constitution, if applicable.

This requirement does not apply to plans submitted for parallel processing in accordance with 40 CFR 51 Appendix W, paragraph 2.3 .1(d).

### Revised VOC Applicability Thresholds for Seven Coun ties

Technical Support for SIP Submittal dated: July 19 , 2012

1. Identification of all regulated pollutants affec ted by the plan. The regulated pollutants addressed by the plan are VOCs.

2. Identification of the locations of affected sour ces including the EPA attainment/non-attainment designation of the locati ons and the status of the attainment plan for the affected areas(s). The plan is applicable to the following counties wh ich are part of the Atlanta 8-hour Ozone Nonattainment Area: Barrow, Bartow, Carroll, Hall, Newton, Spalding, and

Walton.

3. Quantification of the changes in plan allowable emissions from the affected sources; estimates of changes in current actual emi ssions from affected sources or, where appropriate, quantification of changes in actual emissions from affected sources through calculations of the differences bet ween certain baseline levels and allowable emissions anticipated as a result of the revision. The SIP revision is being submitted for the sole pu rpose of incorporating the requirements of Control Technique Guidelines into G eorgia’s SIP.

4. The State’s demonstration that the national ambi ent air quality standards, prevention of significant deterioration increments, reasonable further progress demonstration, and visibility, as applicable, are p rotected if the plan is approved and implemented. For all requests to redesignate a n area to attainment for a national primary ambient air quality standard, unde r section 107 of the Act, a revision must be submitted to provide for the maint enance of the national primary ambient air quality standards for at least 10 years as required by section 175A of

the Act. All applicable standards, increments, RFPs and visi bility will continue to be protected. The SIP revision is being submitted for the sole purpose of incorporating the requirements of Control Technique Guidelines into Georgia’s

SIP.

5. Modeling information required to support the pro posed revision, including input data, output data, models used, justification of mo del selections, ambient monitoring data used, meteorological data used, jus tification for use of offsite data (where used), modes of models used, assumptions, an d other information relevant to the determination of adequacy of the modeling an alysis. No modeling was performed.

6. Evidence, where necessary, that emission limitat ions are based on continuous emission reduction technology. Where necessary, the adopted rules require emission limitations that are based on continuous emission reduction technology.

### Revised VOC Applicability Thresholds for Seven Coun ties

7. Evidence that the plan contains emission limitat ions, work practice standards and recordkeeping/reporting requirements, where necessa ry, to ensure emission

levels. The SIP revision is being submitted for the sole pu rpose of incorporating the requirements of Control Technique Guidelines into G eorgia’s SIP. The revised Georgia Rules ensure these emission levels.

8. Compliance/enforcement strategies, including how compliance will be determined in practice.

Enforcement will be carried out as described in the State/EPA Enforcement Agreement.

9. Special economic and technological justification s required by any applicable EPA policies, or an explanation of why such justificati ons are not necessary. The SIP revision is being submitted for the sole pu rpose of incorporating the requirements of Control Technique Guidelines into G eorgia’s SIP.