# Georgia's Redesignation Request and

Maintenance Plan for the Floyd County Nonattainment Area for the 1997 PM 2.5 

# NAAQS

May 30, 2012

Prepared by:



# Georgia Department of Natural Resources

Environmental Protection Division

Air Protection Branchii

Executive Summary

This document contains Georgia's request under the Clean Air Act Amendments of (CAA) of 1990 that the Floyd County nonattainment area be redesignated to attainment with respect to the annual National Ambient Air Quality Standard (NAAQS) for PM 2.5 (1997 fine particulate matter standard, retained i n 2006). The document also includes Georgia’s plan t o maintain attainment of the PM 2.5 standard in Floyd County.

This request is based on three years, 2007-2009, of ambient monitoring data showing attainment of the standard (15.0 μ g/m 3 ) consistent with the clean data policy memo (Steph en Page 12/14/2004); the implementation of permanent and enforceable reducti ons in PM 2.5 and PM 2.5 precursor emissions; compliance with all applicable requirements; and th e Floyd County Maintenance Plan with projections demonstrating maintenance of the standard through t he year 2023.

### Floyd County PM 2.5 

### Nonattainment Area Redesignation Request and Maintenance Plan

iii TABLE OF CONTENTS



### 1.0 Introduction ......................................

................................................... ........................ 1

1.1 Nonattainment Designation and Attainment Demonstrat ion .......................................... 1

1.2 Redesignation Request .............................

................................................... ........................ 2

1.3 Maintenance Plan ..................................

................................................... ........................... 3


### 2.0 Redesignation Request .............................

................................................... ................. 4

2.1 Attainment of the Annual PM 2.5 NAAQS ............................................ .............................. 4 2.1.1 Monitoring Network ................................

................................................... ..................................... 4 2.1.2 Ambient PM 2.5 Data .............................................

................................................... ........................ 6 2.1.3 Clean Data Determination ..........................

................................................... .................................. 6

2.2 Implementation Plan Under Section 110(k) ..........

................................................... ......... 7

2.3 Permanent and Enforceable and Other Reductions in E missions .................................. 7 2.3.1 Source Apportionment of Ambient PM 2.5 .................................................. ..................................... 7 2.3.2 State Control Measures - Georgia ..................

................................................... .............................. 9 2.3.2.1 SO 2 and NO x Controls and SO 2 Limits ........................................... ...................................... 10 2.3.2.2 Smoke Management Plan .............................

................................................... ..................... 15 2.3.3 Federal Control Measures ..........................

................................................... ................................ 16 2.3.3.1 Clean Air Interstate Rule .........................

................................................... .......................... 17 2.3.3.2 Tier 2 Vehicle Standards ..........................

................................................... ......................... 18 2.3.3.3 Heavy-Duty Gasoline and Diesel Highway Vehicles Sta ndards & Ultra Low-Sulfur Diesel Rule ..............................................

................................................... ....................................... 18 2.3.3.4 Large Nonroad Diesel Engines Rule & Ultra Low-Sulfu r Diesel Rule ................................ 18 2.3.3.5 Nonroad Large Spark-Ignition Engines and Recreation al Engines Standard ....................... 19 2.3.3.6 NO x SIP Call in Surrounding States ...................

................................................... ............... 19 2.3.4 SO 2 Emissions Reductions in Upwind States ............

................................................... ................. 19

2.4 Section 110 and Part D Requirements ...............

................................................... ........... 22


### 3.0 Maintenance Plan ..................................

................................................... ................. 23

3.1 Maintenance Demonstration .........................

................................................... ................ 23 3.1.1 Attainment Year Emissions Inventory ...............

................................................... ........................ 24 3.1.1.1 Point Sources .....................................

................................................... ................................ 25 3.1.1.2 Nonpoint Sources ..................................

................................................... ............................ 26 3.1.1.3 Onroad Mobile Sources .............................

................................................... ........................ 27 3.1.1.4 Nonroad Mobile Sources ............................

................................................... ....................... 28 3.1.1.5 Summary of 2007 Emissions Inventory ...............

................................................... ............. 29 3.1.2 Projected Emissions Inventories ...................

................................................... ............................. 29 3.1.2.1 Methods and Projected Inventories .................

................................................... .................. 29 3.1.2.2 Point Sources .....................................

................................................... ................................ 31 3.1.2.3 Nonpoint Sources ..................................

................................................... ............................ 33 3.1.2.4 Onroad Mobile Sources .............................

................................................... ........................ 34 3.1.2.5 Nonroad Mobile Sources ............................

................................................... ....................... 35 3.1.3 Emissions Projections Summary and Demonstration of Maintenance of Attainment ................... 36 3.1.4 Emissions Decreases ...............................

................................................... ................................... 38 3.1.5 Verification of Continued Attainment ..............

................................................... .......................... 39

### Floyd County PM 2.5 

### Nonattainment Area Redesignation Request and Maintenance Plan

iv 3.2 Contingency Provisions.............................

................................................... ..................... 39 3.2.1 Contingency Measure Triggers ......................

................................................... ............................ 39 3.2.2 Schedule and Procedure for Adoption and Implementat ion of Contingency Measures ................ 40 3.2.3 Contingency Measures ..............................

................................................... ................................. 41


### 4.0 Motor Vehicle Emissions Budget ....................

................................................... ........ 43

4.1 Pollutants ........................................

................................................... ................................ 43

4.2 Methodology .......................................

................................................... ............................ 44

4.3 Motor Vehicle Emissions Budgets and Safety Margins ................................................. 4 5


### 5.0 Conclusion ........................................

................................................... ...................... 46

6.0 References ........................................

................................................... ....................... 49

### Floyd County PM 2.5 

### Nonattainment Area Redesignation Request and Maintenance Plan

v LIST OF FIGURES

Figure 1-1. PM 2.5 Nonattainment Areas in Georgia ...................

................................................... .. 1 Figure 2-1. Locations of Floyd County PM 2.5 sampling sites. .................................. ....................... 5 Figure 2-2: Average factor contributions for 2003-0 4 at the Atlanta, Floyd County, and Macon STN sites using PMF ...............................

................................................... ................................. 8 Figure 2-3. Locations and 2007 Energy Production o f Coal-fired EGU Facilities in North Georgia ...........................................

................................................... ......................................... 11 Figure 2-4. SO 2 Emissions and Generation from Plant Hammond, 2003 - 2009 ........................ 14 Figure 2-5. SO 2 Emissions and Generation from North Georgia Coal- fired EGU Facilities,

2003 - 2009 .......................................

................................................... ....................................... 14 Figure 2-6. Trend of Aggregated Annual SO 2 Emissions in States With Downwind Contributions to Georgia PM 2.5 Exceeding 0.15 μg/m 3

.................................................. ........ 22

### Floyd County PM 2.5 

### Nonattainment Area Redesignation Request and Maintenance Plan

vi LIST OF TABLES

Table 1-1. PM 2.5 Design Value for Floyd County ....................

................................................... ...... 2 Table 2-1. Floyd Co. PM 2.5 Data Collection Sites............................. ................................................ 6 Table 2-2. Annual and Three-year Average Ambient P M 2.5 Concentrations ................................. 6
Table 2-3. Average factor contributions to PM 2.5 ( μ g/m 3 ) for 2003-04 at the Atlanta, Floyd
County, and Macon STN sites using PMF .............

................................................... ................ 9 Table 2-4. Timetable of State Measure Implementati on ................................................ ............... 10

Table 2-5. Annual SO 2 Emissions and Generation (10 6 MWh) from North Georgia Coal-fired
EGU Facilities, 2003 - 2009 .......................

................................................... ............................ 13 Table 2-6. Timetable of Federal Measure Implementa tion .............................................. ............ 17

Table 2-7. Annual SO 2 Emissions in States With Downwind Contributions to Georgia PM 2.5 Exceeding 0.15 μg/m 3

.................................................. ................................................... ........... 21 Table 3-1. 2007 Emissions Inventory Sources ......

................................................... ....................... 24
Table 3-2. Point Source Emissions for 2007 (tons, annual) ........................................... ................ 25

Table 3-3. Non-EGU Point Source Emissions for 2007 (tons, annual) ................................... ...... 25 Table 3-4. Nonpoint Source Emissions for 2007 (ton s, annual) ........................................ ............ 27 Table 3-5. Largest Nonpoint PM 2.5 Emissions by Source Classification ............... ....................... 27

Table 3-6. Onroad Mobile Source Emissions for 2007 (tons, annual) ................................... ....... 28

Table 3-7. Nonroad Mobile Source Emissions for 200 7 (tons, annual) .................................. ...... 29 Table 3-8. Attainment-year (2007) Emissions Invent ory (tons, annual) ................................ ...... 29

Table 3-9. Bases of Control and Growth Factors for 2017 and 2023 Inventories ....................... 30 Table 3-10. Projected Point Source Emissions (tons ) ................................................. ................... 32

Table 3-11. Non-EGU Point Source Emissions for 202 3 (tons, annual) .................................. ..... 32 Table 3-12. Projected Nonpoint Source Emissions (t ons) .............................................. ............... 33 Table 3-13. Largest Nonpoint PM 2.5 Emissions by Source Classification, Year 2023 .... ............. 34 Table 3-14. Projected Onroad Mobile Source Emissio ns (tons) ......................................... .......... 35 Table 3-15. Projected Nonroad Mobile Source Emissi ons (tons) ........................................ ......... 36 Table 3-16. Projected Emissions – Total of All Sec tors (tons) ....................................... ................ 37

Table 3-17. PM 2.5 Speciation Data ..................................

................................................... .............. 37

Table 3-18. Emissions Decrease ...................

................................................... ................................. 38
Table 4-1. 2023 Motor Vehicle Emissions, Emissions Budgets, and Safety Margins .................. 45 Table 5-1. Summary of Projected SO 2 Emissions – Total of All Sectors (tons) .......... ................. 46 Table 5-2. Summary of Projected NO x Emissions – Total of All Sectors (tons) .......... ................ 47 Table 5-3. Summary of Projected PM 2.5 Emissions – Total of All Sectors (tons) .......... .............. 47

### Floyd County PM 2.5 

### Nonattainment Area Redesignation Request and Maintenance Plan

vii LIST of APPENDICES

Appendix A Source Apportionment of PM 2.5 in Georgia

Appendix B Georgia’s Basic Smoke Management Plan an d Memorandum of Understanding

Appendix C Emissions Inventory Development for Floy d County

Appendix C-1 Development of the Point Source Emissi ons Inventory for 2007 in the SESARM

Region (Version 1.8), January 26, 2011

Appendix C-2 Area and Nonroad 2007 Base Year Invent ories, Final Report, June 2010

Appendix C-3 Mobile Source Emissions Modeling for F loyd County PM 2.5 Maintenance Plan

Motor Vehicle Emissions Budget

Appendix C-4 The Travel Demand Model for the Rome M PO

Appendix C-5 Growth and Control Factors for Aircraf t, Commercial Marine Vessel, and Locomotive Emissions (includes memorandum from K. T hesing and two spreadsheets)

Appendix C-6 Documentation of the 2012 Projection E mission Inventory (VISTAS)

Appendix C-7 Growth Factors for Nonpoint Sources an d Non-EGU Point Sources

Appendix C-8 MACTEC, August 2009. Point Source, On -road, and Fire Base Year, Future Year,

and Control Strategy Emissions Inventories Draft Qu ality Assurance Project Plan

Appendix C-9 E.H. Pechan and Associates, July 29, 2 009. Quality Assurance Project Plan for Nonroad and Area Source Base Year and Future Year Emis sions Inventories

### Floyd County PM 2.5 

### Nonattainment Area Redesignation Request and Maintenance Plan

viii List of Acronyms

Acronym Meaning Acronym Meaning

AEO Annual Energy Outlook FGD Flue Gas Desulfurizat ion

AERR Annual Emissions Reporting

Requirements FR Federal Register

AIRS Aerometric Information Retrieval

System FRM Federal Reference Method

AQS Air Quality Subsystem FRUTS Floyd-Rome Urban Tr ansit Study

CAA Clean Air Act GDOT Georgia Department of Transportation

CAIR Clean Air Interstate Rule GFC Georgia Forestry Commission

CARB California Air Resources Board HC Hydrocarbon

CERR Consolidated Emissions Reporting

Rule HPMS Highway Performance Monitoring System

CFR Code of Federal Regulations ICI Industrial and Commercial/Institutional

CO Carbon Monoxide MOU Memorandum of Understanding

CSAPR Cross-state Air Pollution Rule MOVES Motor Ve hicle Emissions Simulator

DNR Department of Natural Resources MPO Metropolita n Planning Organization

DOT Department of Transportation MVEB Motor Vehicle Emissions Budget

EGAS Economic Growth Analysis System MWe Megawatt E lectrical

EGU Electric Generating Unit MWh Megawatt Hours

EPA Environmental Protection Agency NAA Nonattainme nt Area

EPD Environmental Protection Division NAAQS Nationa l Ambient Air Quality Standard

ERTAC Eastern Regional Technical Advisory

Committee NCD NMIM County Database

### Floyd County PM 2.5 

### Nonattainment Area Redesignation Request and Maintenance Plan

ix Acronym Meaning Acronym Meaning

NEI National Emissions Inventory SCR Selective Cata lytic Reduction

NMIM National Mobile Inventory

Model SEMAP Southeastern Modeling Analysis Plan

NTE Not-To-Exceed SIP State Implementation Plan

NO x Nitrogen Oxides SMP Smoke Management Plan

OAQPS Office of Air Quality

Planning and Standards SO 2 Sulfur Dioxide

PM Particulate Matter SOA Secondary Organic Aerosol s

PM 2.5 Fine Particulate Matter STN Speciated Trends Netwo rk

PMF Positive Matrix Factorization tpy Tons Per Year

ppm parts per million SUV Sport Utility Vehicle

RACM Reasonably Available Control

Measures ULSD Ultra-Low Sulfur Diesel

RACT Reasonably Available Control

Technology VISTAS Visibility Improvement State and Tribal Association of the Southeast

RFP Reasonable Further Progress VMT Vehicle Miles T raveled

SCC Source Classification Code WRD Wildlife Resourc es Division

### Floyd County PM 2.5 

### Nonattainment Area Redesignation Request and Maintenance Plan

1 of 49 

## 1.0 Introduction

This document contains the technical support for th e Georgia Environmental Protection Division's (EPD’s) request that the Floyd County nonattainment area be redesignated as an area attaining the 1997 annual fine particulate matter (PM 2.5 ) National Ambient Air Quality Standard (NAAQS) pursuant to Sections 107(d)(3)(D) and (E) of the Cl ean Air Act (CAA), as amended. This redesignation request was prepared in accordance wi th U.S. EPA Guidance issued in 1992 (memorandum dated September 4 of that year from Joh n Calcagni 1 ).


### 1.1 Nonattainment Designation and Attainment Demonstrat ion In 2005, EPA designated four PM 2.5 nonattainment areas in Georgia: Chattanooga (whic h also includes parts of Alabama and Tennessee), Floyd Cou nty, Atlanta, and Macon. Figure 1-1 shows their locations. The Floyd County nonattainment ar ea is located in the northwest portion of the state and south of Georgia’s portion of the Chattanooga N onattainment Area.



### Figure 1-1. PM 2.5 

### Nonattainment Areas in Georgia

1 “Procedures for Processing Requests to Redesignate Areas to Attainment,” September 4, 1992. John Calcagni, Director, Air Quality Management Division , OAQPS, USEPA.

### Floyd County PM 2.5 

### Nonattainment Area Redesignation Request and Maintenance Plan

2 of 49 EPA made initial designations of nonattainment area s, including the Floyd County nonattainment area, for the 1997 annual PM 2.5 NAAQS on January 5, 2005 (70FR944), and amended th e designations on April 5, 2005 (70FR19844). The obs erved PM 2.5 design value at Floyd County’s nonattainment area monitor violated the annual stan dard, as shown in Table 1-1 below.



### Table 1-1. PM 2.5 

### Design Value for Floyd County

Site Name Monitor ID PM 2.5 Design Value 2001-2003 (μg/m 3 )
Rome-Coosa High School 13-115-0005 15.7

The State of Georgia prepared and submitted a PM 2.5 attainment demonstration plan for the Floyd County Nonattainment Area to EPA Region 4 on Octobe r 27, 2009 (cover date is October 20). The plan was based on modeling of the effects of existi ng and planned control measures on air quality in Floyd County and demonstrated attainment of the sta ndard by April 5, 2010.

Since EPA has determined that the area has met the clean data requirements (76FR 18650) and attained the standard prior to the attainment date (76FR 55776) (see Section 2), the SIP requirements that the October 27, 2009 attainment demonstration was required to fulfill are suspended. The attainment demonstration plan has been withdrawn an d will be replaced with this maintenance plan. Relief from the requirement to submit an attainment demonstration as well as Reasonable Further Progress (RFP), associated RACM, and contingency re quirements upon clean data determination is specified in 40 CFR 51.1004(c) and also in a Decemb er 14, 2004 memo from Stephen Page of U.S. EPA.



### 1.2 Redesignation Request

This document contains Georgia's request that the F loyd County nonattainment area be redesignated to attainment with respect to the annual NAAQS for PM 2.5 (1997 fine particulate matter standard, retained in 2006). Section 107(d) of the CAA state s that an area can be redesignated to attainment if the following conditions are met:

1. The EPA has determined that the NAAQS has been a ttained.

2. The applicable implementation plan has been full y approved by EPA under Section 110(k).

3. The EPA has determined that the improvement in a ir quality is due to permanent and enforceable reductions in emissions.

4. The state has met all applicable requirements fo r the area under Section 110 and Part D.

5. The EPA has fully approved a maintenance plan, i ncluding a contingency plan, for the area as required by CAA Section 175A.

### Floyd County PM 2.5 

### Nonattainment Area Redesignation Request and Maintenance Plan

3 of 49 The supporting documentation to show that the above conditions have been met is contained in Sections 2 and 3. EPA’s approval of this document will satisfy the fifth condition.



### 1.3 Maintenance Plan
The maintenance plan (see above) has two required c omponents under Section 175A:

• A demonstration of maintenance of the standard for at least ten years after redesignation; and

• Contingency provisions for prompt correction of any future violations.

Per EPA guidance 2 , the Floyd County PM 2.5 maintenance plan also includes the following eleme nts:

• An attainment year emissions inventory (to support the maintenance demonstration);

• A commitment to continued operation of ambient moni toring equipment in the area; and

• Verification of continued attainment.

The maintenance plan is presented in Section 3.

2 “Procedures for Processing Requests to Redesignate Areas to Attainment,” September 4, 1992. John Calcagni, Director, Air Quality Management Division , OAQPS, USEPA.

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### Nonattainment Area Redesignation Request and Maintenance Plan

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## 2.0 Redesignation Request

As noted in Section 1.2 of this document, Section 1 07(d) of the CAA states that an area can be redesignated to attainment if the following conditi ons are met: 1. The EPA has determined that the NAAQS has been a ttained. 2. The applicable implementation plan has been full y approved by EPA under Section 110(k). 3. The EPA has determined that the improvement in a ir quality is due to permanent and enforceable reductions in emissions. 4. The state has met all applicable requirements fo r the area under Section 110 and Part D. 5. The EPA has fully approved a maintenance plan, incl uding a contingency plan, for the area under CAA Section 175A.

This section of the document includes supporting do cumentation for the following:

• Attainment of the annual PM 2.5 NAAQS based on ambient data from 2007 through 2009 ;

• Approval by EPA of the implementation plan under Se ction 110(k);

• Improvement of air quality with respect to PM 2.5 is due to permanent and enforceable reductions in emissions; and

• The state has met all applicable requirements for t he area under Section 110 and Part D.



### 2.1 Attainment of the Annual PM 2.5 

### NAAQS

A monitoring site is in attainment of the annual PM 2.5 standard when the annual standard design value is less than or equal to 15.0 micrograms per cubic meter (μg/m 3 ) per Appendix N of 40 CFR Part 50. The annual standard design value is the 3 -year average of the annual mean, which is, in turn, the average of one year’s 4-calendar-quarter averages. The data must be complete and qualityassured, consistent with 40 CFR Part 58 requirement s, and other relevant EPA guidance. Therefore, for a single site to meet the standard, the annual design value calculated from the previous three calendar years must be less than or equal to the st andard. For a nonattainment area to achieve attainment, all monitoring sites in the nonattainme nt area must be in attainment.

The Floyd County design value based on data from 20 07 through 2009 is 13.3 μg/m 3 which demonstrates attainment of the standard. The monit oring network and ambient PM 2.5 data are presented below.

2.1.1 Monitoring Network

One PM 2.5 Federal Reference Method (FRM) monitor and one PM 2.5 Speciated Trends Network (STN) monitor were located at the Rome-Coosa High S chool site (13-115-0005) until March 9, 2009. The PM 2.5 FRM monitor was installed in accordance with 40 CF R 58 and had been collecting data since January 18, 1999 (Table 2-1). Its sampl ing schedule was every three days until March 1, 2007, when it started sampling daily. The PM 2.5 speciation monitor had been collecting data since March 3, 2002. Speciated data is useful for determ ining the composition of the particulate matter but cannot be used for the purpose of determining attai nment with the NAAQS. The sampling schedule of the PM 2.5 speciation monitor was every six days. On March 1 0, 2009, the PM 2.5 monitors at the Rome-Coosa High School site (13-115-0005) were relo cated a short distance (less than one mile) to the Rome-Coosa Elementary School site (13-115-0003) . PM 2.5 sampling was continued from the

### Floyd County PM 2.5 

### Nonattainment Area Redesignation Request and Maintenance Plan

5 of 49 Rome-Coosa Elementary School site at the same colle ction frequency. The elementary school site did not collect PM 2.5 data prior to relocation of the samplers from the high school site.

The locations of both monitoring sites are shown in Figure 2-1. PM 2.5 data collection dates at the sites are presented in Table 2-1. As noted above, PM 2.5 sampling has been discontinued at the RomeCoosa High School site (13-115-0005).



### Figure 2-1. Locations of Floyd County PM 2.5 

### sampling sites.

### Floyd County PM 2.5 

### Nonattainment Area Redesignation Request and Maintenance Plan

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### Table 2-1. Floyd Co. PM 2.5 

### Data Collection Sites

Site Name AQS*

Site ID Start Date –

FRM Data Collection End Date -

FRM Data Collection Start Date –

Speciation Data Collection End Date -

Speciation Data Collection

Rome-Coosa High School 13-115-0005 Jan. 18, 1999 March 9, 2009 March 3,

2002 March 9, 2009

Rome-Coosa Elem. School 13-115-0003 March 10, 2009 March 10, 2009

* EPA’s Air Quality System



### 2.1.2 Ambient PM 2.5 

### Data

Table 2-2 shows the annual average PM 2.5 concentrations and the associated 3-year average t hat demonstrate attainment of the standard in Floyd Cou nty. The 2007 – 2009 3-year design value is 13.3 μg/m 3 , which is below the standard of 15.0 μg/m 3 . The table includes annual averages from 2003 through 2009, demonstrating the downward trend in the measured ambient PM 2.5 level in the nonattainment area. The annual average PM 2.5 concentration for 2010 was 13.2 μg/m 3 . This provides continued evidence that the county is meet ing the standard. To date the quality-assured annual average for 2011 is not available.



### Table 2-2. Annual and Three-year Average Ambient P M 2.5 

### Concentrations

Ambient PM 2.5 Concentration (μg/m 3 )

2003 2004 2005 2006 2007 2008 2009 2007 - 2009

16.2 15.6 16.6 15.9 15.7 13.0 11.3 13.3

2.1.3 

### Clean

Data Determination

On April 5, 2011, EPA promulgated its determination (76 FR 18650) that the Floyd County nonattainment area had attained the 1997 annual ave rage PM 2.5 National Ambient Air Quality Standard (NAAQS). This determination was based upo n quality-assured and certified ambient air monitoring data for the 2007-2009 period which show ed a design value of 13.3 μg/m 3 . With the clean data determination, EPA suspended the require ments for the nonattainment area to submit an attainment demonstration, a reasonable further prog ress (RFP) plan, associated RACM, and contingency measures. These requirements are suspe nded as long as the area continues to attain the standard. This final rule became effective on May 5, 2011.

### Floyd County PM 2.5 

### Nonattainment Area Redesignation Request and Maintenance Plan

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### 2.2 Implementation Plan Under Section 110(k)

Section 110(k) of the CAA addresses EPA’s actions o n state implementation plan submittals (completeness, deadline for action by EPA, etc.). A September 4, 1992, memo from John Calcagni of EPA states the following:

“The SIP for the area must be fully approved under section 110(k), and must satisfy all requirements that apply to the area. It should be noted that ap proval action on SIP elements and the redesignation request may occur simultaneously.”

The State of Georgia has prepared and submitted a P M 2.5 attainment demonstration plan for the Floyd County Nonattainment Area. The plan was subm itted for approval to EPA Region 4 on October 27, 2009. As discussed in Section 1.1 of this redesignation request and maintenance plan, the attainment demonstration, associated RACM, RFP, and contingency requirements that the October 27, 2009 SIP revision was required to fulfi ll have been suspended. Therefore, the attainment demonstration has been withdrawn and sub stituted with submittal of this maintenance plan. There are no longer any Section 110(k) requi rements to be met.



### 2.3 Permanent and Enforceable and Other Reductions in E missions

In order for the nonattainment area to be redesigna ted to attainment, the State must demonstrate (and EPA must determine) that the improvement of ambient PM 2.5 concentrations during the years 2007 through 2009 is due to permanent and enforceable re ductions, unless otherwise stated, in emissions that were implemented following the nonattainment d esign value period (2001–2003). This subsection contains Georgia EPD’s demonstration tha t the improved air quality is due to permanent and enforceable emissions reductions. The elements of the demonstration described below are as follows:

• Source apportionment, which links individual, obser ved ambient PM 2.5 species to

specific emissions sources;

• State control measures and associated emissions red uctions;

• Federal control measures and associated emissions r eductions; and

• Reductions in SO 2 emissions from upwind states.



### 2.3.1 Source Apportionment of Ambient PM 2.5

Source apportionment of speciated ambient pollutant measurements is an important tool for the prioritization of pollutant control strategies. Pr esented here are source-apportionment results for 2003-2004 speciated PM 2.5 measurements in the Atlanta, Floyd County, and Mac on areas (Figure 2-2 and Table 2-3). The source-apportionment results a re based on Positive Matrix Factorization (PMF), a factor analytic method that distinguishes correla tion patterns among speciated PM 2.5 measurements in a given location. More detailed information on source apportionment is presented in Appendix A.

### Floyd County PM 2.5 

### Nonattainment Area Redesignation Request and Maintenance Plan

8 of 49 The similarities between the PMF results for the th ree sites show the regional nature of PM 2.5 . The major impacting factors at all sites are secondary sulfates, secondary organic aerosols (SOA), mobile sources, and biomass burning. The Atlanta area, as expected, has higher levels of mobile-source PM 2.5 , compared to Floyd County and Macon. On the other hand, these latter two sites exhibit higher levels of soil dust, and the Macon site exhi bits a relatively high contribution of Lime/Mineral s PM 2.5 . This is likely due to local sources in the indus trial area where the site is located.

0.0 2.0 4.0 6.0 8.0 10.0 12.0 14.0 16.0 18.0

Atlanta Floyd county Maconug/m3 Unspec.
SOA
Sec. Nitrate
Sec. Sulfate
Zn-rich
Cu-rich
Road-dust Oil burning
Na-rich
Lime/Minerals
Soil Biomass burning
Mobile-sources



### Figure 2-2: Average factor contributions for 2003-0 4 at the Atlanta, Floyd County, and Macon STN sites using PMF

These results are useful for an assessment of contr ol strategies. Secondary sulfate makes up approximately five μg/m 3 (32 %) of ambient PM 2.5 , the largest contribution of all of the factors. SOAs make up the next largest contribution at 20%. The contribution of secondary nitrate is only one-fifth of the contribution of sulfate. Contribu tions from all other source-categories were small i n general, though the Macon and Rome sites seem to be affected by local sources related to lime/minerals processing and soil dust re-suspensio n.
Secondary sulfates are formed in the atmosphere fro m SO 2 emissions. As the sulfate fraction is the largest fraction of ambient PM 2.5 , it is evident that controlling SO 2 emissions (generated primarily by coal-burning EGUs) would reduce PM 2.5 levels throughout the state. Secondary nitrates ar e associated with NO x emissions from combustion, primarily combustion in EGUs and in on-road mobile sources. SOAs are associated with biogenic emissions (natural emissions from living trees and other vegetation). It is not practical to cont rol biogenic emissions. Biomass burning generates elemental carbon (soot) and is associated with wild fires, prescribed burning, and wood-fired boilers. In addition to NO x , mobile sources generate elemental carbon.

### Floyd County PM 2.5 

### Nonattainment Area Redesignation Request and Maintenance Plan

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### Table 2-3. Average factor contributions to PM 2.5 

### ( μ g/m 3 

### ) for 2003-04 at the Atlanta,

Floyd County, and Macon STN sites using PMF

Factor Atlanta Floyd County Macon

Unspecified 2.32 2.97 1.81

SOA 2.55 3.46 3.81

Sec. Nitrate 0.99 1.05 0.74

Sec. Sulfate 4.82 5.10 4.67

Zn-rich 0.03 0.03 0.03

Cu-rich 0.07 0.03 0.02

Road-dust 0.12 0.13 0.11

Oil burning 0.03 0.04 0.04

Na-rich 0.43 0.42 0.33

Lime/Minerals 0.05 0.24 0.59

Soil 0.29 0.61 0.67

Biomass burning 1.06 1.31 1.50

Mobile sources 2.78 1.61 2.12



### 2.3.2 State Control Measures - Georgia

Based on source factor analysis, Georgia’s control strategy is focused on the reduction of emissions associated with secondary sulfates and nitrates, bi omass burning, and mobile sources. Control of SO 2 is the most important component of the strategy, a s secondary sulfates make up the largest controllable contribution to ambient PM 2.5 . State measures that target reduction of these em issions

are:

• SO 2 and NO x controls on EGUs [Rule (sss)];

• SO 2 limits on EGUs [Rule (uuu)]; and

• Smoke Management Plan.

### Floyd County PM 2.5 

### Nonattainment Area Redesignation Request and Maintenance Plan

10 of 49 Table 2-4 shows the timetable of implementation of these measures as well as the species controlled by each. The correlation between the drop in PM 2.5 annual averages and the implementation of the control measures, particularly Georgia Rule 391-3-1 -.02(2)(sss), lends strong evidence that the improvements in air quality are a result of reducti on in emissions and not a meteorologicallyinfluenced phenomenon. Detailed discussions of the measures are presented in the following subsections.



### Table 2-4. Timetable of State Measure Implementation

Measure Species

controlled 2001 ‘02 ‘03 ‘04 ‘05 ‘06 ‘07 ‘08 ‘09 ‘10

PM 2.5 ann. avg. (μg/m 3 ), Floyd Co. 16.2 14.6 16.2 15.6 16.6 15.9 15.7 13.0 11.3 13.2

Rule (sss) SO 2 , NO x *

Smoke Management Plan PM, NO x

Rule (uuu) SO 2
* Controls were required on December 31, 2008, but were actually started up in the first half of the
year.

2.3.2.1 SO 2 and NO x Controls and SO 2 Limits

Atmospheric secondary sulfate is formed from emissi ons of SO 2 . Coal-fired EGUs are by far the most significant source of SO 2 emissions in Georgia and in the Southeast. Georgi a’s Multipollutant Rule [391-3-1-.02(2)(sss)] requires flue gas desulf urization (FGD) and selective catalytic reduction (SCR) controls on the majority of coal-fired EGUs i n Georgia. This state-enforceable rule was promulgated in 2007 for the purposes of lowering oz one and PM 2.5 concentrations by controlling precursor emissions and for reducing mercury deposi tion. The FGD controls reduced SO 2 emissions rates from the affected emissions units by at least 95 percent and the SCR controls reduced NO x emissions rates by approximately 85 percent. The S O 2 and NO x controls were required in support of EPA’s CAIR rule, which was promulgated in 2005 and required statewide caps for NO x and SO 2 beginning in 2009 and 2010, respectively. The CAIR rule is discussed further in Section 2.3.3.

Georgia Rule (uuu), SO 2 Emissions from Electric Utility Steam Generating U nits, is a companion rule to Rule (sss) and is both state and federally enforceable upon approval. Both of these rules wer e implemented in response to CAIR and require emissio ns reductions consistent with CAIR’s original schedule starting in 2009. The rule requires 95% r eduction of SO 2 emissions from the majority of Georgia’s coal-fired EGUs, with the requirement bei ng phased in from 2010 through 2016. All four EGUs at Plant Hammond are required to demonstrate 9 5% reduction starting on January 1, 2012.

It has been well demonstrated that ambient secondar y sulfate in a given location can be significantly affected by SO 2 emissions from distant sources. Therefore, second ary sulfate in Floyd County is due

### Floyd County PM 2.5 

### Nonattainment Area Redesignation Request and Maintenance Plan

11 of 49 not only to SO 2 emissions from Plant Hammond, located inside the c ounty, but also to SO 2 emissions from other coal-fired EGUs in north Georgia. Figur e 2-3 shows the locations of the coal-fired EGU facilities in the northern half of Georgia as well as their respective energy production (in million megawatt-hours) in the year 2007. Plant Bowen, whi ch is approximately 30 miles from Floyd County’s ambient monitor, was a close second to Pla nt Scherer in energy production and historically has been by far the highest SO 2 -emitting facility in the state. Plant Scherer, wh ich was first in Georgia in energy production, is located approximat ely 120 miles from the Floyd County monitor. The facilities shown in the figure comprise seven o f the ten coal-fired EGU facilities that were operated in Georgia in 2007. In 2007, the energy p roduced by the seven facilities made up 97 percent of the statewide energy production from coa l-fired facilities.



### Figure 2-3. Locations and 2007 Energy Production o f Coal-fired EGU Facilities in North Georgia

### Floyd County PM 2.5 

### Nonattainment Area Redesignation Request and Maintenance Plan

12 of 49 The required FGD control implementation date varies by EGU, starting on December 31, 2008. SO 2 controls were actually started on five units in May 2008. SO 2 controls were operating for the entire year of 2009 as follows:

• Plant Hammond – controls on 4 of 4 units;

• Plant Bowen – controls on 2 of 4 units; and

• Plant Wansley – controls on 1 of 2 units.

SO 2 controls on a third unit at Plant Bowen and on the second unit at Plant Wansley began operation on April 1, 2009.

Rule (sss) requires SCR controls to be operated yea r-round, starting at six EGUs in 2008 and 2009 (Bowen Units 2, 3, and 4; Wansley Units 1 and 2; an d Hammond Unit 4). However, these NO x controls were already in place and operating during the ozone season by the end of 2003. The Title V permit of each of the above facilities has been a mended to permit operation of the FGD and SCR controls.

Table 2-5 shows the annual SO 2 emissions for Plant Hammond and the other six coal -fired facilities in north Georgia for the period 2003 through 2009. The table also includes the electrical generation, a measure of production, for the facilities for the same time period. This data is presented in graphical form in Figures 2-4 and 2-5.

Comparing 2003 and 2009 for Plant Hammond, SO 2 emissions were reduced by 97.5% whereas generation was down by 22.1%. For the seven facili ties, SO 2 emissions were reduced by 50.4% and generation was down by only 4.5%. These statistics provide clear evidence that the reduction in PM 2.5 concentration is due to permanent and enforceable controls rather than to reduced production.

### Floyd County PM 2.5 

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13 of 49 

### Table 2-5. Annual SO 2 

### Emissions and Generation (10 6 

### MWh) from North Georgia

Coal-fired EGU Facilities, 2003 - 2009

Facility 2003 2004 2005 2006 2007 2008 2009

Hammond SO 2 (tpy) 35,900 37,700 39,500 40,600 47,800 12,500* 900*

generation 4.79 4.11 4.64 4.27 5.09 4.32 3.73

Bowen SO 2 (tpy) 164,900 165,900 186,500 206,400 196,800 148,100* 54,800*

generation 21.9 21.9 23.3 23.7 24.0 23.4 22.9

Branch SO 2 (tpy) 64,800 70,100 90,500 96,000 98,400 94,000 60,100

generation 8.28 7.97 10.3 10.8 10.9 10.7 6.82

McDonough SO 2 (tpy) 23,900 22,700 27,700 28,800 28,500 24,300 15,900

generation 3.75 3.52 3.92 4.07 4.07 3.43 2.34

Scherer SO 2 (tpy) 83,900 79,700 82,900 74,200 76,500 77,700 69,500

generation 21.3 24.6 25.5 24.5 26.5 25.7 24.3

Wansley** SO 2 (tpy) 94,000 99,000 101,500 96200 93,900 74,300* 7400*

generation 13.7 14 15.1 14.8 16.1 15.5 11.8

Yates SO 2 (tpy) 44,900 50,600 66,500 75,500 77,200 68,200 45,500

generation 6.73 6.22 7.37 7.49 8.10 7.37 4.90

TOTAL SO 2 Tons/yr 512,300 525,700 595,100 617,700 619,100 499,100 254,100

TOTAL Generation 10 6 MWh 80.45 82.32 90.13 89.6 94.76 90.42 76.79

Ambient PM 2.5 , Floyd Co. annual

average (ug/m 3) 16.2 15.6 16.6 15.9 15.7 13.0 11.3

Source: EPA Clean Air Markets Division * SO 2 control, required by Georgia Rule (sss), was opera tional on one or more EGUs for partial or full year ** does not include emissions from facility’s gas-f ired units

### Floyd County PM 2.5 

### Nonattainment Area Redesignation Request and Maintenance Plan

14 of 49 0 10000 20000 30000 40000 50000 60000

2003 2004 2005 2006 2007 2008 2009 0 1 2 3 4 5 6

SO2 (tpy)

gen (million MWh)



### Figure 2-4. SO 2 

### Emissions and Generation from Plant Hammond, 2003 - 2009

0 100000 200000 300000 400000 500000 600000 700000

2003 2004 2005 2006 2007 2008 2009 0 10 20 30 40 50 60 70 80 90 100

SO2 (tpy)

gen (million MWh)



### Figure 2-5. SO 2 

### Emissions and Generation from North Georgia

Coal-fired EGU Facilities, 2003 - 2009

### Floyd County PM 2.5 

### Nonattainment Area Redesignation Request and Maintenance Plan

15 of 49 2.3.2.2 Smoke Management Plan

Forestry and agriculture, two of the Georgia’s most significant industries, utilize prescribed burning practices to support production. Prescribed burnin g is the controlled application of fire to existing vegetative fuels to accomplish planned land managem ent objectives or to mitigate catastrophic wildfires. In addition to managing forests and agr icultural resources, prescribed burning helps protect lives and property by reducing accumulation s of forest fuels and helps to sustain imperiled species and ecosystems. The Georgia General Assemb ly enacted the Georgia Prescribed Burning Act to authorize and promote the use of prescribed burning for community protection and for silvicultural, environmental, and wildlife purposes

. Large prescribed burns can produce significant PM 2.5 emissions. These emissions, if not properly managed, can reach smoke-sensitive areas and have s ignificant negative impacts on the air quality in these areas. Smoke-sensitive areas include Georgia ’s heavily populated areas and PM 2.5 nonattainment areas. Without a prescribed burning program, there is a higher probability of catastrophic wildfires, which can threaten personal property and can have even higher negative impacts on air quality.

To prevent negative air quality impacts from prescr ibed burning, Georgia DNR and the Georgia Forestry Commission formulated and adopted Georgia’ s Basic Smoke Management Plan (SMP) dated April 16, 2008. The plan was developed in ac cordance with EPA’s “The Interim Air Quality Policy on Wildland and Prescribed Fires” and the dr aft EPA guidance document, “Elements of a Smoke Management Program.” The purpose of the SMP is to allow fire to function in its natural role in maintaining healthy wildland ecosystems while pr otecting public health and welfare by mitigating the impacts of air pollutants from wildland and pre scribed fires on air quality and visibility. The p lan is a necessary component in determining Exceptional Events related to prescribed burning and is an element of Georgia’s Regional Haze SIP. The Georg ia Forestry Commission (GFC), Georgia DNR’s EPD, and Georgia DNR’s Wildlife Resources Div ision (WRD) signed a Memorandum Of Understanding (MOU) to implement the SMP on April 1 6, 2008. The SMP and the MOU are included as Appendix B.

The SMP identifies the following components that sh ould be considered in the planning of prescribed burns:

• smoke mitigation,

• smoke dispersion evaluation,

• public notification, and

• air quality monitoring.

Smoke mitigation, smoke dispersion evaluation, and air quality monitoring are important to mitigating the effects of prescribed burns on air q uality in smoke-sensitive areas. Smoke mitigation is accomplished by avoiding smoke-sensitive areas, performing burns under favorable smoke dispersion conditions, and managing the generation and release of emissions over time. Smoke dispersion evaluations are performed by GFC-certifi ed prescribed fire managers and are supported by the GFC’s full-time fire weather meteorologist. Air quality monitoring and forecasting, performed by Georgia EPD, provides important air qu ality data to assist fire managers with their decisions on when to schedule prescribed burns.

### Floyd County PM 2.5 

### Nonattainment Area Redesignation Request and Maintenance Plan

16 of 49 In addition to mitigating the impacts of prescribed burns on air quality, the implementation of an SMP has benefits with regard to the computation of air quality design values. Design values are statistical measures of historical ambient pollutan t concentrations that are compared to EPA’s air quality standards to determine if attainment of the standard has been achieved. An atypical event, such as an unusually large forest fire, can produce PM 2.5 emissions that will significantly increase ambient concentration measurements, and, therefore, design value computations, in a nonattainment area. EPA will allow the atypical ambient measurem ents to be excluded from the design value computation if the fire event is deemed to be an “e xceptional event”. In order for a large fire to qualify as an exceptional event, the EPA has stated that a state must demonstrate that a certified SMP was in place at the time of the event or that the s tate must ensure that the burner employs basic smoke management practices.

All outdoor burning is subject to enforcement throu gh law enforcement officers of GFC, DNR and local law enforcement. The enforcement authority i s the Georgia Forest Fire Protection Act, as well as EPD’s authority to enforce Federal and State air quality regulations and laws. In addition, GFC has the authority to void certification of certifie d prescribed burners if investigation reveals that disregard for basic smoke management practices cont ributed to smoke intrusion into a smokesensitive area. This measure is State enforceable. It is not necessary for the continued maintenance of attainment in the Floyd area. However, implemen tation of the SMP will support the maintenance of the annual PM 2.5 NAAQS.



### 2.3.3 Federal Control Measures

Federal control measures related to ambient PM 2.5 are focused on the reduction of emissions associated with sulfates, nitrates, and direct PM. Federal measures that targeted reduction of these emissions between nonattainment designation and the clean data period are as follows:

• Clean Air Interstate Rule/Cross State Air Pollution Rule;

• Tier 2 Vehicle Standards;

• Heavy-Duty Gasoline and Diesel Highway Vehicles Sta ndards and Ultra-Low Sulfur Diesel (ULSD) Rule;

• Large Nonroad Diesel Engines Rule and ULSD Rule;

• Non-Road Spark Ignition Engines and Recreational En gines Standard; and

• NO x SIP Call in Surrounding States.

All of the measures were in place prior to 2007, wi th the exception of the large nonroad diesel rule (effective in 2008) and CAIR. Reductions associate d with vehicles and engines will increase during the maintenance period as older engines are removed from service and replaced by new engines.

Table 2-6 shows the timetable of implementation of these measures as well as the species controlled by each. The continuous drop in PM 2.5 concentration from 2005 through 2009 demonstrates that the improvement of air quality is due to the implementa tion of the control measures. Detailed discussions of the measures are presented in the fo llowing subsections.

### Floyd County PM 2.5 

### Nonattainment Area Redesignation Request and Maintenance Plan

17 of 49 

### Table 2-6. Timetable of Federal Measure Implementat ion

Species controlled 2001 ‘02 ‘03 ‘04 ‘05 ‘06 ‘07 ‘08 2009

PM 2.5 ann. avg. (μg/m 3 ) 16.2 14.6 16.2 15.6 16.6 15.9 15.7 13.0 11.3

Clean Air Interstate Rule (CAIR) NO x *

Tier 2 vehicle standards NO x Heavy Duty Engine Standard, first phase NO x , VOC

Heavy Duty Engine Standard, second phase, and ULSD PM, SO 2

Large Nonroad Diesel Rule and ULSD PM, NO x , SO 2
Nonroad Spark Ignition and Recreational Vehicle NO x , VOC, CO

NO x SIP Call in Surrounding States NO x

* also requires SO 2 controls after 2009

2.3.3.1 Clean Air Interstate Rule

On May 12, 2005, the U.S. EPA promulgated the “Rule To Reduce Interstate Transport of Fine Particulate Matter and Ozone (Clean Air Interstate Rule)” referred to as CAIR. This rule established the requirement for States to adopt rules limiting the emissions of NO x and sulfur dioxide (SO 2 ) and a model rule for the states to use in developing th eir rules. The purpose of the CAIR was to reduce interstate transport of precursors to fine particul ate and ozone.

The CAIR rule applied to fossil-fuel-fired electric generation units (EGUs), including certain cogeneration units, with nameplate capacities of gr eater than 25 MWe. This rule set annual state caps for NO x and SO 2 in two phases, with the Phase I caps starting in 2 009 and 2010, respectively. Phase II caps for NO x and SO 2 were to become effective in 2015.

As part of the CAIR rule, EPA determined that Georg ia contributed significantly to downwind PM 2.5 nonattainment areas and/or interfered with maintena nce of the PM 2.5 NAAQS (70 FR 25246-25250). Accordingly, a State CAIR rule [Georgia rule 391-3- 1-.02(13)] was promulgated that, for the most part, mirrors the provisions of the federal rule.

### Floyd County PM 2.5 

### Nonattainment Area Redesignation Request and Maintenance Plan

18 of 49 On July 11, 2008, the U.S. District Court of Appeal s in the District of Columbia vacated the Clean Air Interstate Rule and remanded it to EPA. A rehe aring of the Court’s decision was requested and granted. On December 23, 2008, the court remanded CAIR to EPA without vacatur (i.e., the rule was still in place). EPA was directed to correct t he deficiencies in CAIR that were identified in the court’s decision.

To replace CAIR, EPA promulgated the final Cross-St ate Air Pollution Rule (76 FR 48208) on August 8, 2011. The Cross-State rule imposes restr ictions on emissions of NO x and SO 2 from states identified as having significant impacts on ozone a nd/or PM 2.5 NAAQS attainment or as interfering with maintenance of these same standards in downwin d states. The requirements of the Cross-state Rule were to become effective in 2012 and 2014 whic h is beyond the 2007-to-2009 clean data period for Floyd County. However, on December 30, 2011, t he U.S. Court of Appeals for the D.C Circuit Court issued a ruling to stay CSAPR pending judicia l review. Regardless of the timing of the transition from CAIR to CSAPR or the resulting cour t-ordered interstate transport remedy, emissions of NO x and SO 2 have declined significantly and are expected to co ntinue to decrease in the future due to the continuation of CAIR and Georgia’s own E GU emission rules.

2.3.3.2 Tier 2 Vehicle Standards

Federal Tier 2 vehicle standards will reduce NO x emissions from passenger vehicles. The standards require all passenger vehicles in a manufacturer’s fleet, including light-duty trucks and sport utilit y vehicles (SUVs), to meet an average standard of 0.0 7 grams of NO x per mile. Implementation began in 2004 and was completely phased in by 2007. The Tier 2 standards will also cover passenger vehicles over 8,500 pounds gross vehicle weight rat ing (the larger pickup trucks and SUVs), which are not covered by the current Tier 1 regulations. For these vehicles, the standards were phased in beginning in 2008 with full compliance in 2009. Th e new standards require vehicles to be 77% to 95% cleaner than those on the road prior to impleme ntation of Tier 2. The Tier 2 rule also reduced the sulfur content of gasoline to 30 parts per mill ion (ppm) starting in January of 2006. Sulfur occu rs naturally in gasoline but interferes with the opera tion of catalytic converters on vehicles resulting in higher emissions. Lower-sulfur gasoline is necessa ry to achieve the Tier 2 vehicle emission standards.

2.3.3.3 Heavy-Duty Gasoline and Diesel Highway Vehicles Sta ndards & Ultra Low-Sulfur Diesel Rule

New U.S. EPA standards designed to reduce NO x and VOC emissions from heavy-duty gasoline and diesel highway vehicles (14001 pounds or more) bega n to take effect in 2004. A second phase of standards and testing procedures, which began in 20 07, will reduce particulate matter from heavyduty highway engines and will also reduce highway d iesel fuel sulfur content to 15 ppm to prevent damage to the emission control devices. The total program is expected to achieve a 90% reduction in particulate matter (PM) emissions and a 95% reducti on in NO x emissions for these new engines using low sulfur diesel, compared to older engines using diesel with higher sulfur content. SO 2 emissions will also be reduced due to the lower fue l sulfur content.

2.3.3.4 Large Nonroad Diesel Engines Rule & Ultra Low-Sulfu r Diesel Rule

In May 2004, the U.S. EPA promulgated new rules for large nonroad diesel engines, such as those used in construction, agricultural, and industrial equipment, to be phased in between 2008 and 2014. The nonroad diesel rules also reduce the allowable sulfur in nonroad diesel fuel by over 99%. Prior

### Floyd County PM 2.5 

### Nonattainment Area Redesignation Request and Maintenance Plan

19 of 49 to 2006, nonroad diesel fuel averaged about 3,400 p pm sulfur. The rule limits nonroad diesel sulfur content to 500 ppm in 2006 and 15 ppm in 2010. The combined engine and fuel rules would reduce NO x and PM emissions from large nonroad diesel engines by over 90%, compared to older engines using diesel with higher sulfur content. SO 2 emissions will also be reduced due to the lower fu el sulfur content.

2.3.3.5 Nonroad Large Spark-Ignition Engines and Recreatio nal Engines Standard

This standard, effective in July 2003, regulates NO x , hydrocarbons (HC) and carbon monoxide (CO) for groups of previously-unregulated nonroad engine s. The new standard applies to all new engines sold in the United States and imported after these standards began and apply to large spark-ignition engines (forklifts and airport ground service equip ment), recreational vehicles (off-highway motorcycles and all-terrain-vehicles), and recreati onal marine diesel engines. The regulation varies based upon the type of engine or vehicle.

The large spark-ignition engines contribute to ozon e formation and ambient CO and PM levels in urban areas. Tier 1 of this standard was implement ed in 2004 and Tier 2 started in 2007. Like the large spark-ignition engines, recreational vehicles contribute to ozone formation and ambient CO and PM levels. For the off-highway motorcycles and all -terrain-vehicles, model year 2006, the new exhaust emissions standard was phased-in by 50% and for model years 2007 and later at 100%. Recreational marine diesel engines over 37 kilowatt s are used in yachts, cruisers, and other types of pleasure craft. Recreational marine engines contri bute to ozone formation and PM levels, especially in marinas. Depending on the size of the engine, t he standard began phasing in during 2006.

When all of the nonroad spark-ignition engines and recreational engines standards are fully implemented, an overall 72% reduction in HC, 80% re duction in NO x , and 56% reduction in CO emissions are expected by 2020. These controls wil l help reduce ambient concentrations of ozone, CO, and fine PM.

2.3.3.6 NO

x SIP Call in Surrounding States

In October 1998, the U.S. EPA made a finding of sig nificant contribution of NO x emissions from certain states and published a rule that set ozone season NO x budgets for the purpose of reducing regional transport of ozone (63 FR 57356). This ru le, referred to as the NO x SIP Call, called for ozone season controls to be put on utility and indu strial boilers, as well as internal combustion engines in 22 states in the Eastern United States. A NO x emissions budget was set for each state and the states were required to develop rules that woul d allow the state to meet their budget. A NO x trading program was established, allowing sources t o buy credits to meet their NO x budget as opposed to actually installing controls. The emiss ion budgets were to be met by the beginning of 2004.



### 2.3.4 SO

2 

### Emissions Reductions in Upwind States

As noted previously, secondary sulfate concentratio ns in a given location can be significantly affected by SO 2 emissions from distant sources. During the period of 2003 through 2009, SO 2 emissions from coal-fired electric generation facil ities upwind of Georgia have been significantly reduced.

### Floyd County PM 2.5 

### Nonattainment Area Redesignation Request and Maintenance Plan

20 of 49 EPA promulgated the Cross-State Air Pollution Rule (76 FR 48208) on August 8, 2011, and projected future emissions to support the rulemaking. Modeli ng in support of the Cross-State Rule has established linkages between emissions from upwind states and ambient PM 2.5 concentrations in downwind receptor states. EPA’s projections indica te that 2012 emissions for the base case (which disallows reductions from existing or future CAIR c ontrols) from ten upwind states will contribute 0.15 μg/m 3 (1 % of the 1997 annual PM 2.5 standard) or more to ambient PM 2.5 concentrations in Georgia’s 2012 projected nonattainment area (Atlant a). The ten states are Alabama, Illinois, Indiana, Kentucky, North Carolina, Ohio, Pennsylvania, South Carolina, Tennessee, and West Virginia. [Source: Appendix D of the Air Quality Modeling Fin al Rule Technical Support Document, June 2011, docket item EPA-HQ-OAR-2009-0491-4140.]

Table 2-7 shows the SO 2 emissions trends from coal-fired EGU facilities in the ten upwind states during the period 2003 through 2009. The total SO 2 emissions from the ten states dropped approximately 15 percent from 2003 to 2007 and over 50 percent from 2003 to 2009. The trend of aggregated SO 2 emissions from these states is presented in Figure 2-6.

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### Nonattainment Area Redesignation Request and Maintenance Plan

21 of 49 

### Table 2-7. Annual SO 2 

### Emissions in States With Downwind Contributions to Georgia PM 2.5 

### Exceeding 0.15 μg/m 3

State 2003 2005 2007 2009

AL 458,622 460,072 447,189 277,972

IL 365,333 326,632 272,571 229,364

IN 804,829 870,812 714,529 413,726

KY 529,559 500,224 379,837 252,002

NC 462,041 500,936 370,826 110,948

OH 1,175,905 1,085,485 954,646 600,687

PA 967,185 985,508 951,186 573,618

SC 203,956 217,386 172,726 97,941

TN 339,536 266,081 237,231 108,042

WV 539,858 467,082 371,996 174,583

TOTAL 5,846,824 5,680,218 4,872,738 2,838,883

Source: EPA Clean Air Markets Division, Acid Rain Program

EPD understands that the emissions reductions in th e upwind states are not permanent and enforceable reductions in Georgia. However, we bel ieve that the reductions provide further evidence that the reduced PM 2.5 levels in Georgia during the period 2007-2009 are due to SO 2 emissions reductions achieved both within and outside Georgia . The majority of upwind reductions are due to state rules or consent orders requiring reduced SO 2 emissions. With the promulgation of the CrossState Air Pollution Rule, it is highly unlikely tha t these reductions will be reversed in the future. (It should be noted that on December 30, 2011, the U.S. Court of Appeals for the D.C Circuit Court issued a ruling to stay CSAPR pending judicial revi ew. Regardless of the timing of the transition from CAIR to CSAPR, or the resulting court-ordered interstate transport remedy, emissions of SO 2 from upwind states have declined significantly and are expected to continue to decrease in the future.)

### Floyd County PM 2.5 

### Nonattainment Area Redesignation Request and Maintenance Plan

22 of 49 0 1,000,000 2,000,000 3,000,000 4,000,000 5,000,000 6,000,000 7,000,000

2003 2005 2007 2009SO2 (tons)
Upwind States



### Figure 2-6. Trend of Aggregated Annual SO 2 

### Emissions in States With Downwind

Contributions to Georgia PM 2.5 

### Exceeding 0.15 μg/m 3



### 2.4 Section 110 and Part D Requirements

Section 110 of the CAA contains the requirements fo r state implementation plans (SIPs). The purpose of a SIP is to provide for the implementati on, maintenance, and enforcement of national primary ambient air quality standards. Part D, Sub part 1, of CAA Title I (Sections 171 to 179) contains general requirements for areas that have b een designated nonattainment. As stated in Section 1.1 of this maintenance plan, Floyd County was designated as nonattainment for the 1997 annual fine PM standard in April of 2005. The coun ty is not now and has not previously been designated nonattainment for any other NAAQS.

Georgia EPD submitted a PM 2.5 nonattainment plan for Floyd County per Title I Pa rt D. With the determination that the Floyd County nonattainment a rea has attained the 1997 annual fine PM standard (Section 2.1.3), the area is no longer sub ject to the nonattainment provision of CAA Section 110 and Part D requirements for demonstrating attai nment, RFP, associated RACM, and contingency for areas designated as nonattainment with the NAAQ S. Therefore, the nonattainment plan was subsequently withdrawn. All other Section 110 and Part D requirements pertaining to the Floyd County area have previously been approved or are cu rrently subject to approval by EPA.

### Floyd County PM 2.5 

### Nonattainment Area Redesignation Request and Maintenance Plan

23 of 49 

## 3.0 Maintenance Plan

Section 175A of the Clean Air Act Amendments of 199 0 defines the general framework of a maintenance plan. The core provisions of Section 1 75A are a quantitative demonstration of maintenance of the standard (PM 2.5 in this case) and contingency provisions for promp t adoption of corrective measures if attainment is not maintained . Per guidance from EPA, 3 this maintenance plan includes a method to verify continued attainment to support the maintenance demonstration. Per the same guidance, this plan also includes a plan to us e the ambient monitoring network for verification of continued attainment or, if applicable, for trig gering contingency provisions.



### 3.1 Maintenance Demonstration

Section 175A of the CAA requires a state that is re questing redesignation to submit a revision to its SIP which provides for maintenance of the applicabl e standard for a minimum of 10 years after the redesignation date. Section 107(d)(3)(D) provides EPA up to 18 months from receipt of a complete submittal to process a redesignation request. Ther efore, Georgia EPD is providing a demonstration of maintenance through the year 2023.

There are two generally-accepted methodologies for demonstrating maintenance. Under the first method, an emissions inventory is compiled for one of the three years which are used to show clean (i.e., attaining) ambient data (see Section 2.1). This year is the baseline or attainment year. Emissions projections are formulated for the final year of the maintenance period and for intermediate years. If each of the projected emiss ion levels is less than the emission level for the attainment year, maintenance of the standard is dem onstrated. This assumes that ambient concentrations will remain below the standard if fu ture annual emissions are kept below the inventoried emissions in the chosen attainment year . Under the second maintenance demonstration method, air quality modeling is used to project amb ient pollutant concentrations and annual design values for the final year and intermediate years. If all of the modeled, rolling, 3-year averages of the annual design values are below the standard, mainte nance is demonstrated.

Georgia EPD has adopted the method of comparing att ainment year emissions to projected emissions for this maintenance plan. This approach has been used in the previous maintenance plans submitted by EPD and approved by EPA. The following sections discuss the attainment year inventory, the projected inventories, and verification of continue d attainment.

3 “Procedures for Processing Requests to Redesignate Areas to Attainment,” September 4, 1992. John Calcagni, Director, Air Quality Management Division , OAQPS, USEPA.

### Floyd County PM 2.5 

### Nonattainment Area Redesignation Request and Maintenance Plan

24 of 49 3.1.1 Attainment Year Emissions Inventory Georgia EPD has selected 2007 as the year for the a ttainment year emissions inventory. 2007 is one of the three years (2007–2009) on which Floyd Count y’s clean data determination is based. The pollutants inventoried and addressed in this mainte nance plan are direct PM 2.5 , SO 2 , and NO x . The following emissions sectors are included in the inv entory:

• Point sources (EGU and non-EGU).

• Nonpoint sources (including fire),

• Onroad mobile sources, and

• Nonroad mobile sources (including marine vessels, a ircraft, and rail). The 2007 inventory, with the exception of on-road m obile emissions, was prepared for Georgia by the contractors for the Southeastern Modeling, Anal ysis, and Planning (SEMAP) project. SEMAP is funded by the same ten states that participated in the Visibility Improvement – State and Tribal Association of the Southeast (VISTAS) project. Und er the SEMAP project, emissions estimates are reported by county and source classification code ( SCC). The SEMAP emissions inventories were developed using data from a number of sources, incl uding state and local agencies and EPA’s National Emissions Inventory (NEI). Georgia EPD de veloped in-house the 2007 inventory of onroad mobile emissions.

The data sources for the attainment-year emissions inventories are summarized in Table 3-1. Additional details on the data sources and inventor y methods are presented in the following subsections and in Appendix C.



### Table 3-1. 2007 Emissions Inventory Sources

Emissions Source Sector Inventory Source Version / Year Generated Basis

Point – EGU SEMAP

Georgia Power Co. Version 1.8, 2011 EPA’s NEI

Point – non-EGU SEMAP Version 1.8, 2011 EPA’s NEI

Nonpoint SEMAP Version 1.1, 2010 EPA’s NEI



### Onroad Mobile GDOT 2011 Georgia DOT [travel demand model and Highway Performance Monitoring System (HPMS)] and MOVES2010a



### Nonroad Mobile SEMAP Final Report, 2010 NMIM2008, 2007 NMIM County Database, 2008 NEI, ERTAC

### Floyd County PM 2.5 

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25 of 49 3.1.1.1 Point Sources

Point sources captured in the inventory include sta tionary sources whose actual emissions equal or exceed 100 tons per year of SO 2 , NO x , or particulate matter. Emissions from point sour ces have been calculated for EGU and non-EGU sources.

Plant Hammond, which includes four EGUs, is the lon e electric generation facility inside the nonattainment area. The non-EGU point sources in F loyd County are as follows:

• Temple–Inland Rome Lumber Mill,

• Temple–Inland Rome Linerboard Mill,

• Metal Container Corporation,

• Packaging Products Corporation, and

• General Shale Brick Plant 40.

2007 emissions of SO 2 , NO x , and PM 2.5 from EGU and non-EGU facilities are presented in T able 3- 2. The Temple–Inland Rome Linerboard Mill is by fa r the largest source of emissions from nonEGU point sources. Emissions from the individual n on-EGU point sources are shown in Table 3-3.



### Table 3-2. Point Source Emissions for 2007 (tons, annua l)

Pollutant EGU (Plant

Hammond) Non-EGU Total Point

SO 2 47,809 3,466.6 51,275 NO x 7,558 2,607.0 10,165 PM 2.5 572 380.6 953



### Table 3-3. Non-EGU Point Source Emissions for 2007 (tons , annual)

Pollutant T-I Rome

Lumber T-I Rome

Linerboard Metal

Container Packaging

Products Gen. Shale

Br. Plt. 40

SO 2 0.0 3337.5 0.1 0.0 129.0 NO x 0.0 2591.2 13.4 2.5 0.0 PM 2.5 0.0 379.1 1.3 0.2 0.0

The 2007 point source inventory is based on the Nat ional Emissions Inventory (NEI) reports for reporting years 2005, 2007, and 2008. Emissions fr om sources that reported for 2007 were generally

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26 of 49 used as reported. For facilities with 2005 and 200 8 emissions (but no 2007 emissions), 2007 emissions were estimated based on a linear interpol ation between facility level 2005 and 2008 emissions on a pollutant-by-pollutant basis to calc ulate facility-level 2007 emissions. For facilitie s with only 2008 data (no 2007 or 2005 data available ), the SIC growth factors from the VISTAS Best & Final inventory were used to backcast 2008 report ed emissions to 2007. For facilities with only 2005 data (no 2007 or 2008 data available), the SIC growth factors from the VISTAS Best & Final inventory were used to project 2005 reported emissi ons to 2007. After the above backcasting and projecting was performed, additional adjustments we re made for facilities where only 2005 data were available and the facility did not operate in 2007 or operated for only part of 2007. In additio n, PM augmentation was performed to generate missing e missions estimates for filterable and primary PM 2.5 , filterable and primary PM10, and condensable PM. See Appendices C and C-1 for more details on the development of the 2007 point source emissions inventory.

3.1.1.2 Nonpoint Sources

Nonpoint sources captured in the inventory include stationary sources whose emissions levels of SO 2 , NO x , and particulate matter are each less than 100 ton s per year. Emissions from nonpoint sources in 2007 were obtained from the SEMAP nonpoi nt source inventory Version 1.1, which was developed by Pechan. A default 2007 nonpoint sourc e inventory was created that includes all of the source categories covered by the 2008 nonpoint sour ce NEI.

For all source categories except industrial and com mercial/institutional (ICI) fuel combustion, emissions data from the 2008 nonpoint source NEI we re directly incorporated when the NEI emissions were based on 2007 emissions activity dat a. The NEI emissions estimates were recalculated to reflect 2007 activity levels when t he NEI emissions reflected 2006 or 2008 activity levels. Emissions associated with activity reflect ed in the point source inventory were removed from the nonpoint inventory.

For ICI fuel combustion, the 2008 nonpoint source N EI developed emissions activity estimates rather than emission estimates. Because of the pot ential importance of these source categories and the availability of methodological improvements, Pe chan utilized an emissions estimation method for ICI fuel combustion that incorporates a few ref inements to the NEI method. These emissions were supplemented with carry-forward categories fro m Georgia’s 2005 CERR submission grown using EPA’s Economic Growth Analysis System (EGAS). For more information regarding the SEMAP nonpoint inventory, please refer to Appendice s C and C-2.

The 2007 nonpoint source emissions for Floyd County are presented in Table 3-4. The largest contributors to SO 2 emissions were coal-fired and residual-oil-fired i ndustrial boilers. The largest contributors to NO x emissions were industrial wood-fired and coal-fire d boilers. The largest contributors to PM 2.5 emissions were industrial wood-fired boilers and r oad dust from unpaved roads.

Emissions from fires in 2007 were obtained from the SEMAP final “actual” fire emissions inventory and are shown in Table 3-4. This inventory was dev eloped using 2007 burned area data submitted by Georgia, as well as updated fuel consumption and em issions factors.

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### Table 3-4. Nonpoint Source Emissions for 2007 (tons, an nual)

Pollutant Nonpoint

(excluding fire) Fire Total Nonpoint SO 2 743 16 758 NO x 877 59 936 PM 2.5 1645 210 1855

The 2007 level of PM 2.5 emissions from nonpoint sources, excluding fire, w as 1645 tons. This quantity accounted for over 50 percent of total PM 2.5 emissions in Floyd County. The top three nonpoint source classifications for PM 2.5 emissions were industrial wood-fired boilers, dust from unpaved roads, and residential open burning of hous ehold waste (see Table 3-5).



### Table 3-5. Largest Nonpoint PM 2.5 

### Emissions by Source Classification

SCC Description 2007 PM 2.5 (tons)

2102008000 Stationary Fuel Comb /Industrial /Wood / Total:

All Boiler Types 797

2296000000 Unpaved Roads /All Unpaved Roads /Total:

Fugitives 438

2610030000 Open Burning /Residential /Household Was te 103

3.1.1.3 Onroad Mobile Sources

U.S. EPA’s MOVES2010a mobile source emissions model was run in inventory mode to generate 2007 on-road mobile source emissions of SO 2 , NO x , and PM 2.5 . The 2007 onroad mobile source emissions for Floyd County are presented in Table 3 -6.

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### Table 3-6. Onroad Mobile Source Emissions for 2007 (tons, annual)

Pollutant Onroad

Emissions SO 2 14 NO x 3378 PM 2.5 117

The following non-default inputs to the MOVES model were used:

• registration distribution by age,

• vehicle population,

• vehicle miles traveled (VMT), and

• hourly temperature and relative humidity.

The age distribution and vehicle population inputs were based on 2002 vehicle counts by MOBILE6 vehicle type obtained from R.L. Polk & Company. Th e vehicle population was grown to 2007 using a combination of Georgia Department of Revenue regi stration data (for buses and motorcycles) and the change in person population estimates from the U.S. Census (for the other MOBILE6 vehicle types). VMT fractions were based on MOVES defaults by source type and adjusted using GDOT count data.

Actual 2007 temperature and humidity data extracted from the "NCD20090531" version of the county database in EPA's National Mobile Inventory Model were used as meteorological inputs to MOVES2010a for 2007. For a detailed discussion on how the on-road mobile emission inventory was developed, see Appendices C, C-3, and C-4.

3.1.1.4 Nonroad Mobile Sources

The nonroad sector is comprised of nonroad engines included in EPA’s NONROAD model, such as recreational marine and land-based vehicles, farm, construction and industrial machinery, and lawn and garden equipment. This sector also includes eng ines not modeled in NONROAD, specifically aircraft, commercial marine vessels, and locomotive s. There are no commercial marine vessel emissions sources in Floyd County. 2007 nonroad mo bile emissions are presented in Table 3-7.

Emissions from NONROAD model source categories in 2 007 were obtained from the SEMAP final nonroad mobile sources emissions inventory. These e missions were calculated using EPA’s latest National Mobile Inventory Model, NMIM2008, which in corporates EPA’s latest NONROAD model (NONROAD2008) and reflects all of EPA’s final nonro ad standards to date. The county/monthly gasoline profile assignments in the County/Year/Mon th table and the gasoline fuel profiles in the Gasoline table of the 2007 NMIM county-level databa se (NCD) were updated with data provided by the state of Georgia. For more information regardi ng the SEMAP nonroad inventory, please refer to Appendices C and C-2. 2007 Emissions from aircraft and locomotives were obtained from the

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29 of 49 SEMAP final nonroad mobile source emissions invento ry. For more information regarding the SEMAP marine, aircraft, and locomotives inventory, please refer to Appendices C and C-5.



### Table 3-7. Nonroad Mobile Source Emissions for 2007 (ton s, annual)

Pollutant (tons) Nonroad -

except air and rail Aircraft Locomotive Total Nonroad

SO 2 22.5 0.1 6.4 29 NO x 419.7 0.8 575.0 996 PM 2.5 43.8 2.1 19.9 66

3.1.1.5 Summary of 2007 Emissions Inventory

The total 2007 Floyd County emissions of SO 2 , NO x , and PM 2.5 are presented for each source sector in Table 3-8. The majority of SO 2 emissions, by far, are from point sources. The ma jority of NO x emissions is from point and onroad mobile sources. The majority of PM 2.5 emissions are from nonpoint and point sources.



### Table 3-8. Attainment-year (2007) Emissions Invent ory (tons, annual)

Pollutant (tons) Point

Total Point

EGU Point

NonEGU Nonpoint Onroad

Mobile Nonroad

Mobile Total

SO 2 51,275 47,809 3,467 758 14 29 52,077

NO x 10,165 7,558 2,607 936 3,378 996 15,475

PM 2.5 953 572 381 1,855 117 66 2991

3.1.2 Projected Emissions Inventories

As discussed previously, Georgia EPD is providing a demonstration of maintenance through the year 2023 (the maintenance year). Emissions projections to support maintenance through 2023 have been prepared for the years 2017 and 2023. In addition, emissions have been calculated by interpolation for the years 2014 and 2020. Emissions for these a dditional years provide additional reference points for periodic assessment of maintenance of th e standard. Maintenance period emissions controls, projection methods, and projected invento ries are discussed in the remainder of this subsection.

3.1.2.1 Methods and Projected Inventories Projected emissions inventories are calculated by a pplying applicable control and growth factors to the 2007 emissions of individual sources or source categories. The control and growth factors may

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30 of 49 apply for some or all of the years 2008 (year follo wing attainment inventory) through 2023 (out year). The bases used to determine these factors a re summarized in Table 3-9.



### Table 3-9. Bases of Control and Growth Factors for 201 7 and 2023 Inventories

Source Category Control Basis Growth Factor Basis

Point – EGU Implementation of GA rule (sss)

for SO 2 and NO x controls; VISTAS 2012 projection inventory Coal consumption forecasts in 2010 Annual Energy Outlook (AEO)

Point – non-EGU Regulatory review - no additional

controls defined at this time EGAS growth factors by SCC and county for 2017 and 2023.

Nonpoint Regulatory review - no additional

controls defined at this time EGAS growth factors by SCC for 2017 and 2023.

Nonpoint – fire No additional controls anticipated No growth anticipated

Onroad Mobile MOVES inventory mode (PM 2.5 ,

NO x , SO 2 ) for 2023. All known Federal controls. MOVES inventory mode (PM 2.5 , NO x , SO 2 ) for 2023. Vehicle population growth from human population projections. Vehicle miles traveled (VMT) growth from Georgia DOT.

Nonroad Mobile NMIM 2008 NMIM 2008

Nonroad Mobile – marine, aircraft, and rail SEMAP (Pechan) control factors

by SCC for 2017 and 2023 SEMAP (Pechan) growth factors by SCC for 2017 and 2023

The pollutants whose emissions are projected are SO 2 , NO x , and direct PM 2.5 . As with the attainment inventory, emissions from the following sectors are projected:

• Point sources (EGU and non-EGU).

• Nonpoint sources (including fire).

• Onroad mobile sources.

• Nonroad mobile sources (including marine vessels, a ircraft, and rail). The projected inventories are presented in the foll owing subsections. The methods used to develop the emissions projections are presented in more det ail in Appendix C.

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31 of 49 3.1.2.2 Point Sources

EGU point source emissions in 2017 and 2023 were es timated using growth factors and control factors. Growth factors were calculated based on c oal consumption for the southeastern region in the Energy Information Administration’s AEO2010 report. The SO 2 control factor due to Flue Gas Desulfurization (FGD) was assumed to be 95% accordi ng to the VISTAS 2012 Projection Emissions Inventory (see Appendices C and C-6). Georgia’s Ru le (sss) requires SO 2 controls on all four of Plant Hammond’s EGUs on December 31, 2008. The SO 2 controls on the four EGUs at Plant Hammond will be operating at all times going forwar d from 2009, whereas the controls were operated for only 55 percent of the 3-year attainme nt period (36 months from 2007 through 2009). In addition, Georgia Rule (uuu) requires 95% reduct ion of SO 2 for all four of Plant Hammond’s EGUs beginning January 1, 2012. The NO x control factor due to Selective Catalytic Reductio n (SCR) was assumed to be 82.5% according to the VIST AS 2012 Projection Emissions Inventory. Georgia’s Rule (sss) requires NO x control, with a year-round operation date of Decem ber 31, 2008, on only one (Unit 4) of Hammond’s four units. The PM 2.5 control factor associated (as a co-benefit) with the new SO 2 controls was assumed to be 50% based on Table 5.4- 1 on page 5.4-24 of EPA’s document "Stationary Source Control Techniques Docu ment for Fine Particulate Matter" (EC/R Incorporated, 1998).

As noted in subsection 2.3.3, EPA promulgated CSAPR in 2011 but the rule was stayed later in the year. When the rule was promulgated, Georgia was i dentified as a covered state and, therefore, would have been required to comply with statewide a llocations of SO 2 and/or NO x emissions from covered EGUs starting in 2012. The future of the r ule is not known at this time and, therefore, the rule’s requirements have not been incorporated into the emissions projections presented here. Any further reductions that may ultimately be required by the Cross-State Rule will only strengthen the case for maintenance of the NAAQS as documented in this plan.

Projected EGU point source emissions are presented in Table 3-10. The projections show a dramatic reduction in SO 2 emissions as well as significant reductions in NO x and PM 2.5 emissions. Emissions levels for 2014 were calculated by linear interpola tion between 2007 and 2017. Emissions levels for 2020 were calculated by linear interpolation betwee n 2017 and 2023.

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### Table 3-10. Projected Point Source Emissions (tons )

Pollutant 2007

(attainment) 2014 2017 2020 2023

EGU SO 2 47,809 16,038 2,422 2,466 2,509 NO x 7,558 5,526 4,655 4,738 4,821 PM 2.5 572 375 290 295 300

Non-EGU SO 2 3,467 3,627 3,696 3,777 3,857 NO x 2,607 2,741 2,798 2,922 3,045 PM 2.5 381 399 407 427 446

Total Point SO 2 51,275 19,666 6,119 6,242 6,366 NO x 10,165 8,267 7,453 7,660 7,866 PM 2.5 953 774 697 722 747

Projected non-EGU point source emissions are shown in Table 3-10 (county totals) and in Table 3-11 (by facility, 2023 only). The emissions for 2017 a nd 2023 were estimated using SCC-specific and county-specific growth factors generated with EPA’s Economic Growth Analysis System version 5.0 (EGAS 5.0). Appendix C-7 contains the SCC-specific growth factors for Floyd County. The projections show moderate increases in emissions of all three pollutants. No additional future controls can be defined for non-EGU point sources a t this time. Emissions levels for 2014 and 2020 were calculated by interpolation as described above

.



### Table 3-11. Non-EGU Point Source Emissions for 2023 (t ons, annual)

Pollutant T-I Rome

Lumber T-I Rome

Linerboard Metal

Container Packaging

Products Gen. Shale

Brick Plt. 40

SO 2 0.0 3675.3 0.1 0.0 181.9 NOx 0.0 3025.8 16.2 3.0 0.0
PM 2.5 0.0 444.4 1.8 0.2 0.0

Projected total point source emissions (sum of EGU and non-EGU) are shown in Table 3-10. The projections show dramatic decreases in emissions of SO 2 as well as moderate decreases in emissions of NO x and PM 2.5 .

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Nonpoint source emissions, excluding fire, in futur e years 2017 and 2023 were estimated using SCCand county-specific growth factors generated with E GAS 5.0. Appendix C-7 contains the SCCspecific growth factors for Floyd County. No addit ional future controls can be defined for these sources at this time.

Projections of nonpoint source emissions are presen ted in Table 3-12. Emissions from fire in future years 2017 and 2023 were assumed to be the same as 2007 emissions. The projections show a small increase in emissions of SO 2 as well as moderate increases in emissions of NO x and PM 2.5 .



### Table 3-12. Projected Nonpoint Source Emissions (t ons)

Pollutant 2007

(attainment) 2014 2017 2020 2023

Nonpoint (excluding fire) SO 2 743 768 779 791 803 NO x 877 967 1,006 1,045 1,084 PM 2.5 1,645 1,862 1,954 2,039 2,123

Fire SO 2 16 16 16 16 16 NO x 59 59 59 59 59 PM 2.5 210 210 210 210 210

Total Nonpoint SO 2 758 784 794 807 819 NO x 936 1,026 1,066 1,104 1,144 PM 2.5 1,855 2,072 2,164 2,249 2,333

The top three nonpoint source classifications for 2 023 PM 2.5 emissions are industrial wood-fired boilers, dust from unpaved roads, and residential o pen burning of household waste (see Table 3-13). Projected PM 2.5 emissions from these three source classifications make up over 70 percent of total projected PM 2.5 emissions.

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### Table 3-13. Largest Nonpoint PM 2.5 

### Emissions by Source Classification, Year 2023

SCC Description 2023 PM 2.5 (tons)

2102008000 Stationary Fuel Comb /Industrial /Wood / Total:

All Boiler Types 1044

2296000000 Unpaved Roads /All Unpaved Roads /Total:

Fugitives 567

2610030000 Open Burning /Residential /Household Was te 133

3.1.2.4 Onroad Mobile Sources

EPD ran U.S. EPA’s MOVES2010a mobile source emissio ns model in inventory mode to generate 2023 onroad mobile source emissions of SO 2 , NO x , and PM 2.5 . Intermediate-year emissions were generated by interpolating between 2007 and 2023. The following non-default inputs to the model were used:

• Vehicle age distribution,

• average speed distribution,

• vehicle population.

• vehicle miles traveled (VMT),

• road type distribution,

• ramp fraction, and

• hourly temperature and relative humidity.

The vehicle age distribution was based on R.L. Polk & Co. registration data. MOVES defaults were used for Heavy-Duty Diesel Vehicle Class 8B. Perso n population growth projections for the Floyd County Metropolitan Planning Organization (MPO) are a were used to calculate the 2023 vehicle population. The 2023 annual VMT were calculated by Georgia DOT using travel demand model outputs and HPMS counts, as well as speed distribut ion, road type distribution, and ramp fraction. Temperature and humidity inputs were assumed to be the same as year 2007.

The projected onroad mobile source emissions levels are presented in Table 3-14. Onroad emissions of all three pollutants trend downward significantl y during the maintenance period. The trend in SO 2 is of less importance since onroad mobile sources e mit very little SO 2 . For a detailed discussion on how the onroad mobile emission inventory was develo ped, see Appendices C, C-3, and C-4.

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### Table 3-14. Projected Onroad Mobile Source Emissions (t ons)

Pollutant (tons) 2007

(attainment) 2014 2017 2020 2023

SO 2 14.1 11.6 10.5 9.4 8.3 NO x 3378.3 

### 2270.9 1796.2 1321.6 847.0
PM 2.5 117.3 

### 79.9 63.9 47.8 31.8

3.1.2.5 Nonroad Mobile Sources

Projections of nonroad emissions in 2017 and 2023, excluding air and rail sources, were calculated using NMIM2008 with the same meteorological inputs as for 2007. Defaults in NMIM 2008 were used for other inputs.

Growth factors for all aircraft engine and airport- related SCCs were based on landing and take-off operation (LTO) projections available from the Fede ral Aviation Administration’s Terminal Area Forecasts (FAA, 2010). Growth rates for military ai rcraft were held constant at 2007 levels. No control factors were applied to aircraft emissions.

Growth factors for freight rail sector emissions we re based on fuel consumption forecasts. For passenger and commuter rail, growth factors were de veloped from national forecasts of intercity rail diesel consumption and commuter rail diesel consump tion. Control factors were based on U.S. EPA’s locomotive engine regulatory impact analysis and associated emission factor guidance.

The nonroad mobile source emissions projections are presented in Table 3-15. Total emissions of all three pollutants trend downward significantly durin g the maintenance period. As with onroad sources, the downward trend in SO 2 is of less importance since nonroad sources emit v ery little SO 2 . For a detailed discussion on how the nonroad mobile emissions projections were developed, see Appendix C.

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### Table 3-15. Projected Nonroad Mobile Source Emissions (t ons)

Pollutant (tons) 2007

(attainment) 2014* 2017 2020* 2023

Nonroad**
SO 2 22.5 0.6 0.7 NO x 419.7 223.0 170.5 PM 2. 5 43.8 28.6 22.0

Aircraft SO 2 0.1 0.1 0.1 NO x 0.8 0.8 0.8 PM 2.5 2.1 1.9 1.9

Locomotive SO 2 6.4 0.3 0.3 NO x 575.0 389.1 307.9 PM 2.5 19.9 9.7 6.9

Tot. Nonroad SO 2 29 9 1 1 1 NO x 996 728 613 546 479 PM 2.5 66 48 40 36 31 * interpolation to 2014 and 2020 performed only for total nonroad emissions ** excluding aircraft and locomotive emissions

3.1.3 Emissions Projections Summary and Demonstration of Maintenance of Attainment

The consolidated emissions projections for all Floy d County sources are presented in Table 3-16. Emissions of SO 2 and NO x drop significantly from 2007 to 2023. This is a r eflection of the implementation of the majority of state and federal controls during the first half of the maintenance period. Overall, emissions of SO 2 and NO x are projected to decline by 86 percent and 33 perc ent, respectively, over the course of the maintenance pe riod.

Emissions of PM 2.5 are flat from 2007 to 2017 and rise slightly from 2017 through 2023. This is a reflection of an increase in nonpoint source emissi ons (primarily industrial wood boilers and road dust) which is partially offset by reductions in th e point and mobile sectors. The overall rise in PM 2.5 is 5.0 percent of attainment year emissions. There fore, further evaluation is needed to judge whether the increase in PM 2.5 emissions, in combination with the decreases in SO 2 and NO x emissions, is likely to provide for maintenance of the standard.

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### Table 3-16. Projected Emissions – Total of All Sectors (tons)

Pollutant (tons) 2007

(attainment) 2014 2017 2020 2023 % change, 2007 - 2023

SO 2 52,077 20,471 6,925 7,060 7,194 - 86.2 NO x 15,475 12,292 10,928 10,632 10,336 - 33.2 PM 2.5 2,991 2,973 2,965 3,054 3,142 + 5.0

Each of the three pollutants is characterized by a different relationship between emissions and air quality. Therefore, simply summing the emissions o f the pollutants does not provide a meaningful indicator of the combined air quality impact of the se emission changes. A more appropriate indicator is the percentage change in emissions for each emit ted pollutant, weighted according to the air quality impact for each.

For this purpose, Georgia EPD examined PM 2.5 speciation data available from the EPA Air Explore r Web site for 2007-2009 for the Floyd County monitor (see Table 3-17). The 3-year average of this data suggests that ambient PM 2.5 in Floyd County consists of approximately 45.2 per cent sulfate, 1.9 percent nitrate, 45.3 percent organic particulate ( which consists of directly-emitted primary organic matter and atmospherically formed secondary organic aerosol), 4.0 percent miscellaneous inorganic particulate (sometimes labeled ‘‘crustal particles’ ’), and 3.6 percent other types of particulate matt er. Therefore, using a conservative assumption that all of the organic particulate is primary organic matter, direct PM 2.5 species make up 49.3 percent (sum of 45.3 and 4.0) of the total ambient PM 2.5 .



### Table 3-17. PM 2.5 

### Speciation Data

Site and Year sulfate

( μ g/m 3 ) nitrate

( μ g/m 3 ) organic

particulate ( μ g/m 3 ) crustal

( μ g/m 3 ) other

( μ g/m 3 ) Total

( μ g/m 3 )

Rome-Coosa HS 2007 8.17 0.33 7.55 0.57 0.49 17.10

Rome-Coosa HS 2008 6.45 0.22 5.85 0.45 0.50 13.46

Rome-Coosa ES 2009 3.96 0.22 5.21 0.65 0.50 10.54

Average 6.2 0.3 6.2 0.6 0.5 13.7 Percent of Total 45.2 1.9 45.3 4.0 3.6 100.0

Georgia EPD used a conservative approach that assum es that the full ambient concentration of organic particulate matter plus miscellaneous inorg anic particulate matter will vary in accordance with changes in total nonattainment area emissions of direct PM 2.5 . This analysis thus assumes that the direct PM 2.5 component of ambient PM 2.5 will increase by the 5.0 percent projected increas e in direct PM 2.5 emissions. This approach was used by U.S. EPA in its evaluation and approval of the annual PM 2.5 redesignation request for the Evansville, Indiana, nonattainment area (see 76 FR 29695 and 76 FR 59527).

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38 of 49 In the Floyd County analysis, the baseline concentr ation is conservatively assumed to be 15.0 μ g/m 3

. Direct PM 2.5 is estimated to contribute 49.3 percent, or 7.4 μ g/m 3 , of the 15.0 μ g/m 3 . Georgia EPD’s assessment assumes that the projected increase in d irect PM 2.5 emissions will cause a corresponding 5.0 percent increase in ambient concentrations of P M 2.5 , which would suggest an increase in the ambient concentration of the direct PM 2.5 component by 0.37 μ g/m 3

. However, Georgia EPD believes that this potential i ncrease will be fully offset by a greater decrease in sulfate and nitrate concentrations. The precise decrease in sulfate and nitrate concentrations is a complicated result of emissions reductions not just in Floyd County, but also in many other parts of the Eastern United States. Nevertheless, modeling conducted by EPA for the Cross State Air Pollution Rule (CSAPR) estimated that future Floyd County concentrations with the final CSAPR in place would be 3.0 μ g/m 3 below the standard (2014 Remedy Average case*). I n addition, the emissions reductions that have already occurred hav e brought measured Floyd County concentrations to 13.3 μ g/m 3 (as shown in Table 2-2). Therefore, the 0.37 μ g/m 3 increase in the components associated with direct PM 2.5 would not be expected to yield concentrations abov e the standard. That is, GA EPD believes that maintenanc e of the annual PM 2.5 standard is demonstrated despite the small projected increase in direct PM 2.5 emissions.

* Air Quality Modeling Final Transport Rule Technic al Support Document, docket item EPA-HQOAR-2009-0491-4140

3.1.4 Emissions Decreases

An emissions surplus represents the degree of impro vement (reduction) in 2023 emissions compared to the attainment year (2007) emissions. The surpl uses are shown in Table 3-18 for each pollutant. A positive surplus reflects an emissions decrease f rom the attainment year to 2023. The negative surplus for PM 2.5 reflects a projected increase in emissions. A por tions of the NOx surplus will be allotted to the Motor Vehicle Emissions Budget as a safely margin (see Section 4).



### Table 3-18. Emissions Decrease

Pollutant Surplus

Emissions* 2007 to 2023 (tons)

SO 2 44,883 NO x ** 5,139 PM 2.5 ** -152

* Surplus = (2007 emissions level) – (2023 emission s level) ** These quantities do not reflect allotment to Mot or Vehicle Emissions Budget

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39 of 49 3.1.5 Verification of Continued Attainment Items 5.c and 5.d of the September 4, 1992, EPA gui dance memo outline requirements for verification of continued attainment. Verification of continued attainment is accomplished through operation of the ambient PM 2.5 monitoring network and through periodic updates of the area's emissions inventory. The location and operation of EPD’s FRM monitor in Floyd County are described in Section 2.1 of this plan. During the maintenance period, EPD will continue to operate a federal reference monitor in Floyd County per the requirements of 40 CFR Part 58. The Consolidated Emissions Reporting Rule (CERR) was promulgated by EPA on June 10, 2002 . The CERR was replaced by the Annual Emissions Reporting Requirements (AERR) rule on Dec ember 17, 2008. The most recent triennial inventory for Georgia was compiled for 2008. The l arger point sources of air pollution will continue to submit data on their emissions on an annual basi s as required by the AERR. Emissions from the rest of the point sources, the nonpoint source port ion and the onroad and nonroad mobile sources continue to be quantified on a 3-year cycle. The i nventory will be updated and maintained on a 3- year cycle. As required by the AERR, the next over all emissions inventory will be compiled for 2011.



### 3.2 Contingency Provisions

Section 175A(d) of the Clean Air Act requires that the maintenance plan include provisions for contingency measures that would promptly be impleme nted to correct a violation of the standard, should this occur, after redesignation of an area a s an attainment area. The measures may include rules or other measures that are not yet effective, but EPD agrees to adopt and implement, as expeditiously as practicable, when required by this plan. The minimum requirement for contingency provisions is the implementation of all measures th at were contained in the SIP for the area (i.e., th e nonattainment plan) before the redesignation. In a ddition, EPA guidance (John Calcagni memo dated September 4, 1992) specifies the following pe rtaining to contingency provisions in the maintenance plan:

• identification of additional measures that would be considered for implementation should a violation occur;

• identification of triggers for the implementation o f additional contingency measures; and

• a schedule and procedure for adoption and implement ation of additional measures (with time limit).

3.2.1 Contingency Measure Triggers

Section 175A(d) of the Clean Air Act Amendments req uires that the maintenance plan include provisions for contingency measures that would prom ptly be implemented by the state to correct any violation of the annual PM2.5 NAAQS after redesigna tion of an area as an attainment area. A list of potential contingency measures that could be consid ered for future implementation in such an event should also be included in the maintenance plan.

EPD has developed a contingency plan for the Floyd County PM 2.5 maintenance area. Contingency measures are intended to provide further emission r eductions in the event that violations of the NAAQS occur after redesignation to attainment. Con sistent with this plan, EPD agrees to adopt and implement, as expeditiously as practicable, the nec essary corrective actions in the event that

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40 of 49 violations of the standard occur within the mainten ance area after redesignation to attainment. Contingency measures as described below would be ad opted and implemented within 24 months of a contingency trigger unless EPD has demonstrated tha t technical or economic feasibility warranted a period longer than 24 months.

EPD will use actual ambient monitoring and emission s inventory data as the indicators to determine whether contingency measures would be implemented. In accordance with 40 CFR Part 58, ambient monitoring data that indicates a violation of the a nnual PM 2.5 NAAQS will begin the process to implement these contingency measures according to t he protocols identified below. The contingency plan provides for corrective responses should the N AAQS be violated, or if emissions in the Floyd County maintenance area increase significantly abov e current levels.

Tier I. A Tier 1 trigger is activated when any one of the following conditions occurs:

• the previous calendar year’s annual average PM 2.5 concentration exceeds the standard by 1.5 ug/m 3 or more;

• the annual average PM 2.5 concentration in each of the previous two consecut ive calendar years exceeds the standard by 0.5 ug/m 3 or more;

• the total maintenance area SO 2 emissions in the most recent NEI exceeds the corre sponding attainment-year inventory by more than 10.0 percent ; and

• the total maintenance area PM 2.5 emissions in the most recent NEI exceeds the corresponding attainment-year inventory by more tha n 30.0 percent.

EPD will conduct an evaluation as expeditiously as practicable to determine if the trend is likely to continue. If it is determined that additional emis sion reductions are necessary, EPD will adopt and implement any required measures in accordance with Section 3.2.2.

The PM 2.5 trigger concentrations described above apply to th e PM 2.5 federal reference monitor in the maintenance area. EPD will evaluate a Tier I condi tion, if it occurs, as expeditiously as practicable to determine the cause(s) of the ambient PM2.5 or e missions inventory increase and to determine if a Tier II condition (see below) is likely to occur.

Tier II. A Tier II trigger is activated when any v iolation of the annual PM 2.5 NAAQS at any FRM ambient monitoring station in the Floyd County main tenance area is recorded, based on qualityassured monitoring data. In this event, EPD will conduct a comprehensive study to determine the cause(s) of the ambient PM 2.5 increase and to determine if the increase is likel y to continue and will implement any required measures as expeditiously as practicable, taking into consideration the ease of implementation and the technical and economic fe asibility of selected measures.

3.2.2 Schedule and Procedure for Adoption and Implementat ion of Contingency Measures

EPD will, in the event of 1) a Tier II trigger cond ition or 2) a Tier I condition in which EPD has determined that a Tier II condition is likely to oc cur, conduct a comprehensive study to determine whether or not contingency measures are required fo r the maintenance of the PM 2.5 standard. Since Floyd County may be influenced by emissions from ou tside the maintenance area, the study will attempt to determine whether the trigger condition is due to local emissions, emissions from elsewhere, or a combination of the previous. The c omprehensive analysis, based on quality-assured ambient data, will examine:

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41 of 49 • the severity of the trigger condition;

• the meteorological conditions (in the case of an am bient concentration trigger) associated with the trigger condition;

• potential contributing local emissions sources;

• potential contributing emissions resulting from reg ional or long-range transport;

• the geographic applicability of possible contingenc y measures;

• emission trends, including implementation timelines of potential control measures;

• timelines of “on-the-books” (adopted) measures that are not yet fully implemented [e.g., Georgia Rule (sss) and Rule (uuu) SO 2 controls]; and

• current and recently-identified control technologie s.

The comprehensive study will be completed and submi tted to EPA as expeditiously as practicable but no later than nine months after the Tier I or Tier II trigger is activated. If EPD determines, throug h the comprehensive study, that contingency measures are required for maintenance of the standard, the appropriate corrective measures will be adopted and implemented within 18 to 24 months after the Tier I or II trigger occurs. These control mea sures, which will continue to produce substantial reductions in fine particulate matter and its precu rsors in excess of what is relied upon in this maintenance plan, include the Georgia Multipollutan t Rule, which is described in Section 2.3.2.1 of this maintenance plan, as well as diesel engine ret rofit, replacement, and repowering programs and truck stop electrification programs which are curre ntly being implemented by Georgia EPD.

If the study determines that additional measures ar e required, rules will be adopted no later than 18 months following the date on which the Tier I or Ti er II trigger is activated. Selection of measures will take into consideration the ease of implementa tion as well as technical and economic feasibility. If it is determined that adoption and implementatio n of a rule will take longer than 24 months following the trigger date, EPD will submit for EPA ’s approval a revised schedule for the development and adoption of contingency measures.

3.2.3 Contingency Measures

If the analysis required above determines emissions from the local area are contributing to the trigge r condition, EPD will evaluate those measures as spec ified in Section 172 of the CAA for control options as well as other available measures. If a new measure/control is already promulgated and scheduled to be implemented at the federal or state level, and that measure/control is determined to be adequate, additional local controls may be unnec essary. Under Section 175A(d), the minimum requirement for contingency measures is the impleme ntation of all measures that were contained in the SIP before the redesignation. Currently all su ch measures are in effect for the Atlanta NAA; however, an evaluation of those measures, such as R ACT, can be performed to determine those measures are adequate or up-to-date. In addition t o those identified in Section 3.2.2, contingency measure(s) will be selected from the following type s of measures or from any other measure deemed appropriate and effective at the time the selection is made:

• Reasonably Available Control Measures (RACM) for so urces of SO 2 and PM 2.5 ;

• Reasonably Available Control Technology (RACT) for point sources of SO 2 and PM 2.5 ;

• Expansion of RACM/RACT to area(s) of transport with in the State;

• Mobile source measures; and

• Additional SO 2 and/or PM 2.5 reduction measures yet to be identified.

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42 of 49 Any resulting contingency measure(s) will be based upon cost effectiveness, emission reduction potential, economic and social considerations, ease and timing of implementation, and other appropriate factors.

Adoption of additional control measures is subject to necessary administrative and legal processes. EPD will solicit input from interested and affected persons (stakeholders) in the area prior to selecting appropriate contingency measures. No con tingency measure will be implemented without providing the opportunity for full public participa tion. This process will include issuance of notice s, an opportunity for public hearing, and other measur es required by Georgia law.

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## 4.0 Motor Vehicle Emissions Budget
The transportation conformity rule (40CFR93.100 - 4 0CFR93.129) ensures that projects and plans funded by the Federal Highway Administration and th e Federal Transit Administration conform to air quality SIPs and maintenance plans. In the case of a NAAQS maintenance plan, the rule requires a motor vehicle emissions budget (MVEB) to be establi shed for the last year of the plan’s maintenance period. The rule, at 40CFR93.124(a), describes a m otor vehicle emissions budget as "...the implementation plan's estimate of future [motor veh icle] emissions." Such budgets establish caps on motor vehicle emissions; projected emissions from t ransportation plans and programs must be equal to or less than these caps for a positive conformit y determination to be made. Transportation conformity determinations are required for non-exem pt federally-funded highway and transit projects before they are funded and approved and fo r transportation plans and transportation improvement programs.



### 4.1 Pollutants

For Floyd County, MVEBs will be set for direct PM 2.5 and NO x only. 40 CFR Parts 93.119(f)(7) through (10) identify the PM 2.5 pollutants which must be analyzed for transportati on conformity purposes. These parts of the rule are listed below :

§119(f)(7) - PM

2.5 in PM2.5 areas;

§119(f)(8) - Reentrained road dust in PM 2.5 areas only if the EPA [Environmental Protection Ag ency] Regional Administrator or the director of the State air agency has made a finding that emissions from reentrained road dust within the area are a si gnificant contributor to the PM 2.5 nonattainment problem and has so notified the MPO and DOT [Depart ment of Transportation];

§119(f)(9) - NO x [nitrogen oxides] in PM 2.5 areas, unless the EPA Regional Administrator and t he director of the State air agency have made a findin g that emissions of NO x from within the area are not a significant contributor to the PM 2.5 nonattainment problem and has so notified the MPO and DOT; and

§119(f)(10) - VOC, SO 2 and/or ammonia in PM 2.5 areas if the EPA Regional Administrator or the director of the State air agency has made a finding that any of such precursor emissions from within the area are a significant contributor to the PM 2.5 nonattainment problem and has so notified the MPO and DOT.

Primary, or direct, PM 2.5 emissions must be considered for all transportatio n conformity regional emissions analyses. For Floyd County, NO x must also be considered since EPA has not approved Georgia EPD’s finding that NO x is not a significant contributor to the PM 2.5 nonattainment problem in Floyd County. None of the other pollutants iden tified (re-entrained road dust, VOC, and ammonia) above have been determined by EPA or Georg ia EPD to be significant contributors to PM nonattainment in Floyd County. SO 2 from coal combustion is significant but levels of SO 2 emissions from mobile sources are very low and, therefore, no t significant for transportation conformity
purposes.

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### 4.2 Methodology

In preparation of this Floyd County PM 2.5 Maintenance Plan, EPD worked closely with the Geor gia Department of Transportation (GDOT) and the Floyd-R ome Urban Transportation Study (FRUTS) to develop the estimates of mobile source emissions fo r the Floyd County nonattainment area. FRUTS is the metropolitan planning organization (MPO) for Rome/Floyd County. Mobile source inventories for 2023 were developed using the latest available planning assumptions, the most recent travel demand model, EPA's latest motor vehicle emission f actor model, and vehicle population and age distributions developed from registration data obta ined from R.L. Polk & Company. The methodology used to calculate the highway mobile so urce emissions on which the 2023 MVEBs are based is discussed below.

Emissions from motor vehicles were estimated as a s um of products of vehicle activity measures and vehicle emissions factors. Vehicle activity measur es (e.g. vehicle miles traveled, or VMT) are determined from a county-specific travel demand mod el. Vehicle emissions factors are determined from a motor vehicle emissions model. See Appendic es C, C-3, and C-4 for more details on the development of the travel demand model and the dete rmination of emissions factors.

The MOVES2010a motor vehicle emission model was use d to calculate 2023 emission factors with all currently known 2023 mobile source control rule s in place. The MOVES model was run in Inventory Mode. The emission factors reflect all f ederal controls, e.g., the Federal Motor Vehicle Control Program, including Tier 1 and (beginning wi th 2006 models) Tier 2 tailpipe standards, and the National Low Emission Vehicle program. MOVES20 10a produces three sets of emission factors
per run:

• rate per distance;

• rate per vehicle; and

• rate per profile.

Of these three types of emission factors, the first is multiplied by VMT and the second two by vehicle population. Note that rate-per-profile emi ssions (i.e., vapor venting) are not applicable to PM 2.5 modeling.

The FRUTS travel demand model is developed and main tained by GDOT. Inputs to the model are socioeconomic data and the highway network that con sists of roadway segments (links) and intersections (nodes). Outputs include vehicle act ivity, number of trips, vehicle population, and oth er data. The use of a county-specific travel demand m odel for transportation conformity calculations is consistent with the transportation conformity rule at 40CFR93.122(b) and (d), which requires a network-based travel model emissions estimation met hodology if the use of such procedures has been the previous practice of the MPO. The use of such a methodology has been the previous practice of FRUTS.

Section 93.105(b) of the Transportation Conformity Rule and Sections 106(g) and 106(h) of Georgia's transportation conformity SIP require int eragency consultation for SIP development. Accordingly, a detailed listing of the procedures a nd planning assumptions used for the regional emissions analysis supporting development of the MV EB was presented to the Rome/Floyd interagency consultation committee for review on Se ptember 15, 2011. The assumptions used to develop Rome's conforming Long Range Transportation Plan and Transportation Improvement Program were also used to develop the network and e missions for this maintenance plan MVEB.

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### 4.3 Motor Vehicle Emissions Budgets and Safety Margins

The projected 2023 on-road motor vehicle emissions for direct PM 2.5 and NO x are 31.8 and 847.0 tons, respectively. A budget for SO 2 is not required. On-road emissions of SO 2 are considered to be

“ de-minimis ” (70FR 24283), and, therefore, no budget is necess ary. The on-road mobile emissions, emissions budgets, and safety margins are presented in Table 4-1. A safety margin is necessary to accommodate the variabilities or worst-case scenari os that can occur due to future planning assumptions.

The worst-case daily motor vehicle emissions projec tion for PM 2.5 is 19.5 percent above the projected 2023 on-road emissions. In a worst-case scenario, the needed annual safety margin for the MVEB would be 6.2 tons resulting in an overall MVEB of 38.0 tons per year.

The worst-case daily motor vehicle emissions projec tion for NO x is 17.4 percent above the projected 2023 on-road emissions. In a worst-case scenario, the needed annual safety margin for the MVEB would be 147.4 tons resulting in an overall MVEB of 994.4 tons per year.



### Table 4-1. 2023 Motor Vehicle Emissions, Emissions Bud gets, and Safety Margins

Pollutant Projected 2023

On-Road Emissions (tons) Safety Margin

Allotted to MVEB (%) Safety Margin

Allotted to MVEB (tons) MVEB with Safety

Margin (tons)

PM 2.5 31.8 19.5 6.2 38.0

NO x 847.0 17.4 147.4 994.4

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## 5.0 Conclusion

Section 107(d) of the CAA states that an area can b e redesignated to attainment if the following conditions are met:

1. The EPA has determined that the NAAQS has been a ttained.

2. The applicable implementation plan has been full y approved by EPA under Section 110(k).

3. The EPA has determined that the improvement in a ir quality is due to permanent and enforceable reductions in emissions.

4. The state has met all applicable requirements fo r the area under Section 110 and Part D.

5. The EPA has fully approved a maintenance plan, i ncluding a contingency plan, for the area as required by CAA Section 175A.



### Table 5-1. Summary of Projected SO 2 

### Emissions – Total of All Sectors (tons)

Source 2007

attainment (tons) 2014

(tons) 2017

(tons) 2020

(tons) 2023

(tons)

Point - total 51,275 19,666 6,119 6,242 6,366

Area - total 758 784 794 807 819

Non-road - total 29 9 1 1 1

Onroad 14 12 11 9 8

Total 52,077 20,471 6,925 7,060 7,194

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### Table 5-2. Summary of Projected NO

x 

### Emissions – Total of All Sectors (tons)

Source 2007

attainment (tons) 2014

(tons) 2017

(tons) 2020

(tons) 2023

(tons)

Point - total 10,165 8,267 7,453 7,660 7,866

Nonpoint - total 936 1,026 1,066 1,104 1,144

Non-road - total 996 728 613 546 479

Onroad 3,378 

### 2271 1796 1322 847

Onroad Safety Margin 147.4

Total 15,475 12,292 10,928 10,632 10,483



### Table 5-3. Summary of Projected PM 2.5 

### Emissions – Total of All Sectors (tons)

Source 2007

attainment (tons) 2014

(tons) 2017

(tons) 2020

(tons) 2023

(tons)

Point - total 953 774 697 722 747

Nonpoint - total 1,855 2,072 2,164 2,249 2,333

Non-road - total 66 48 40 36 31

Onroad 117 

### 80 64 48 32

Onroad Safety Margin 6.2

Total 2,991 2,973 2,965 3,054 3,149

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48 of 49 The supporting documentation to show that the above conditions have been met for Floyd County is contained in this document. Based on the 2007-2009 monitored design value for the Floyd County nonattainment area, EPA has published in the Federal Register its final rule that the nonattainment area has attained the 1997 annual ave rage PM 2.5 National Ambient Air Quality Standard (NAAQS). The maintenance demonstration in this document shows that, based on comparison of projected emissions to attainment yea r emissions, emissions are expected to stay at or below levels commensurate with attaining air qualit y through the year 2023 as illustrated by Tables 5-1, 5-2 and 5-3 above. Analysis was presented to demonstrate that the standard will be maintained despite a small, projected increase in direct PM 2.5 emissions. This document also contains provisions for contingency measures should emissions levels or ambient concentrations rise unexpectedly. EPA’s concurrence that the improvement in Floyd Cou nty’s air quality is due to permanent and enforceable reductions in emissions, and EPA’s appr oval of this document will satisfy Items 3 and 5 above. Therefore, Georgia EPD requests that the Fl oyd area be redesignated from nonattainment to attainment with respect to the 1997 annual NAAQS fo r fine particulate matter. In addition, 2023 MVEBs have been presented for onroad mobile emissio ns of direct PM 2.5 and NO x . These emissions budgets are required by EPA’s transportation confor mity rule as tools for ensuring conformance of highway and transit plans with air quality SIPs and maintenance plans.

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## 6.0 References

State of Georgia, Rules for Air Quality Control, Ch apter 391-3-1, Effective September 13, 2011.

US Energy Information Administration, Annual Energy Outlook 2010, April 2010.

USEPA, Air Quality Modeling Final [Cross-state Air Pollution] Rule Technical Support Document, June 2011, Docket ID No. EPA-HQ-OAR-2009-0491-4140.

USEPA, “Approval, and Promulgation of Air Quality I mplementation Plans; Indiana; Redesignation of the Evansville Area to Attainment of the Fine Pa rticulate Matter Standard’; proposed rule, 76 FR 29695.

USEPA, “Clean Data Policy for the Fine Particle Nat ional Ambient Air Quality Standards,” Memorandum from Stephen Page, December 14, 2004.

USEPA, “Determination of Attaining Data for the 199 7 Annual Fine Particulate Standard; Rome, Georgia, Final Rule”; 76 FR 18650 – 18651.

USEPA, “Federal Implementation Plans: Interstate Tr ansport of Fine Particulate Matter and Ozone and Correction of SIP Approvals” [a.k.a. “Cross-Sta te Air Pollution Rule”]; final rule, 76 FR 48208.

USEPA, National Emissions Inventory: inventory year s 2005, 2007, and 2008.

USEPA, “Procedures for Processing Requests to Redes ignate Areas to Attainment,” Memorandum from John Calcagni, September 4, 1992.