Georgia's Redesignation Request 

and Maintenance Plan 

for the 

Atlanta Nonattainment Area 

for the 

1997 PM2.5 NAAQS 

August 16, 2012 

Prepared by: 

Georgia Department of Natural Resources 

Environmental Protection Division 

Air Protection Branch 
Executive Summary 

This document contains Georgia's request under the Clean Air Act Amendments of (CAA) of 1990 that 

the Atlanta nonattainment area be redesignated to attainment with respect to the annual National Ambient 

Air Quality Standard (NAAQS) for PM2_5 (1997 fine patiiculate matter standard, retained in 2006). The 

document also includes Georgia's plan to maintain attainment of the PM2_5 standard in the Atlanta area. 

This request is based on three years, 2008-20 l 0, of ambient monitoring data showing attainment of the 

standard (15.0 Jlg/m3

) consistent with the clean data policy memo (Stephen Page 12/14/2004); the 

implementation of permanent and enforceable reductions in PM2_5 and PM25 precursor emissions; 

compliance with all applicable requirements; and the Atlanta Area Maintenance Plan with projections 

demonstrating maintenance of the standard through the year 2024. 

ii 
Atlanta PM2.s NonattainmentArea 

Redesignation Request and Maintenance Plan 

TABLE OF CONTENTS 

Executive Summary ........................................................................................................................ ii 

1. 0 Introduction ................................................................................................................. I 

1.1 Nonattainmeut Designation and Attainment Demonstration .......................................... 1 

1.2 Redesignation Req nest ....................................................................................................... .4 

1.3 Maintenance Plan ................................................................................................................ 4 

2. 0 Redesignation Request ................................................................................................. 5 

2.1 Attainment of the Annual PM2.5 NAAQS .......................................................................... 5 

2.1. I Monitoring Network ....................................................................................................................... 5 

2. 1.2 Ambient PM25 Data ........................................................................................................................ 8 

2. I .3 Clean Data Determination ............................................................................................................... 9 

2.2 Implementation Plan Under Section 110(1<) ...................................................................... 9 

2.3 Permanent and Enforceable, and Other Reductions in Emissions ................................. 9 

2.3. I Source Apportionment of Ambient PM2.s ..................................................................................... I 0 

2.3.2 State Control Measures- Georgia ................................................................................................. 12 

2.3.2.1 S02 and NO, Controls and S02 Limits ................................................................................ 14 

2.3 .2.2 Smoke Management Plan ..................................................................................................... 20 

2.3.3 Federal Control Measures ............................................................................................................. 22 

2.3.3. I Clean Air Interstate Rule ...................................................................................................... 24 

2.3.3.2 Tier 2 Vehicle Standards and Low-Sulfur Gasoline ............................................................. 25 

2.3.3.3 Heavy-Duty Gasoline and Diesel Highway Vehicles Standards & Ultra Low-Sulfur Diesel 

Rule ........................................................................................................................................ 25 

2.3.3.4 Large Nomoad Diesel Engines Rule & Ultra Low-Sulfur Diesel Rule ................................ 26 

2.3 .3 .5 Nonroad Large Spark -Ignition Engines and Recreational Engines Standard ....................... 26 

2.3.3.6 NOx SIP Call in SmTounding States ..................................................................................... 26 

2.3.4 S02 Emissions Reductions in Upwind States ................................................................................ 27 

2.4 Section 110 and Part D Requirements ............................................................................. 29 

3.0 Maintenance Plan ...................................................................................................... 30 

3.1 Maintenance Demonstration ............................................................................................ 30 

3. I. I Attainment Year Emissions Inventory .......................................................................................... 30 

3. I. I. I Point Sources ........................................................................................................................ 3 I 

3. I. I .2 Nonpoint Sources ................................................................................................................. 32 

3.1.1.3 Omoad Mobile Sources ........................................................................................................ 33 

3. I. I .4 N omoad Mobile Sources ...................................................................................................... 34 

3. I. I .5 Summary of2008 Emissions Inventory ............................................................................... 35 

3. I .2 Projected Emissions Inventories ................................................................................................... 35 

3.1.2.1 Methods and Projected Inventories ...................................................................................... 35 

3.1.2.2 Point Sources ........................................................................................................................ 37 

3 .1.2.3 Nonpoint Sources ................................................................................................................. 3 8 

3.1.2.4 Onroad Mobile Sources ........................................................................................................ 40 

3. 1.2.5 Nonroad Mobile Sources ...................................................................................................... 40 

3.1.3 Emissions Projections Summary and Demonstration ofMaintenance of Attainment.. ................ .42 

3 .1.4 Emissions Decreases ..................................................................................................................... 43 

3. I .5 Verification of Continued Attainment.. ......................................................................................... 44 

iii 
Atlanta PM2.s NonattainmentArea 

Redesignation Request and Maintenance Plan 

3.2 Contingency Provisions ..................................................................................................... 44 

3.2.1 Contingency Measure Triggers ..................................................................................................... 44 

3.2.2 Schedule and Procedure for Adoption and Implementation of Contingency Measures ................ 45 

3.2.3 Contingency Measures .................................................................................................................. 46 

4.0 Motor Vehicle Emissions Bmlget ............................................................................... 48 

4.1 Pollntants ........................................................................................................................... .48 

4.2 Methodology ....................................................................................................................... 49 

4.3 Motor Vehicle Emissions Budgets ami Safety Margius .................................................. 50 

5.0 Conclusion ................................................................................................................. 51 

6. 0 References .................................................................................................................. 54 

iv 
Atlanta PM2.s NonattainmentArea 

Redesignation Request and Maintenance PMn 

LIST OF FIGURES 

Figure 1-1. PM2•5 NonattainmentAreas in Georgia ......................................................................... 2 

Figure 2-1. Locations of Atlanta Area PM2•5 Sampling Sites .......................................................... 6 

Figure 2-2: Average factor contributions for 2003-04 at the Atlanta, Floyd County, and Macon 

STN sites using PMF ................................................................................................................. 1 0 

Figure 2-3. Locations and 2007 Energy Production of Coal-fired EGU Facilities in North 

Georgia ....................................................................................................................................... 15 

Figure 2-4. S02 Emissions and Generation from North Georgia Coal-fired EGU Facilities, 

2003 - 2010 .................................................................................................................................. 20 

Figure 2-5. Trend of Aggregatecl Annual S02 Emissions in States with Downwind 

Contributions to Georgia PM2.5 Exceeding 0.15 )lg/m3 .......................................................... 29 

v 
Atlanta PM2.s NonattainmentArea 

Redesignation Request and Maintenance Plan 

LIST OF TABLES 

Table 1-1. PM2.

5 Design Values for Atlanta Area Monitors 2001-2003 ........................................... 3 

Table 2-1. Atlanta Area PM2.5 Data Collection Sites ........................................................................ 7 

Table 2-2. Annual and 3-year Average Ambient PM2.5 Concentrations ......................................... 8 

Table 2-3. Average factor contributions to PM2.5 (~g/m ) for 2003-04 at the Atlanta, Floyd 

County, and Macon STN sites using PMF ............................................................................... ll 

Table 2-4. Timetable of State Measure Implementation ............................................................... 13 

Table 2-5. Annual S02 Emissions and Generation (106 MWh) from North Georgia Coal-fired 

EGU Facilities, 2003-2010 ...................................................................................................... 18 

Table 2-6. Timetable of Federal Measure Implementation ........................................................... 23 

Table 2-7. Annual S02 Emissions in States With Downwind Conti·ibutions to Georgia PM2.5 

Exceeding 0.15 11g/m3 ................................................................................................................ 28 

Table 3-1. 2008 Emissions Inventory Sources ................................................................................ 31 

Table 3-2. Emissions by EGU facilities in 2008, 2017 and 2024 .................................................... 32 

Table 3-3. Point Source Emissions for 2008 (tons, annual) ........................................................... 32 

Table 3-4. Nonpoint Source Emissions for 2008 (tons, annual) .................................................... 33 

Table 3-5. Largest Nonpoint PM2.5 Emissions by Source Classification ...................................... 33 

Table 3-6. Onroad Mobile Source Emissions for 2008 (tons, annual) .......................................... 33 

Table 3-7. Nonroad Mobile Source Emissions for 2008 (tons, annual) ........................................ 34 

Table 3-8. Attainment-year (2008) Emissions Inventory (tons, annual) ...................................... 35 

Table 3-9. Bases of Control and Growth Factors for 2017 and 2024 Inventories ....................... 36 

Table 3-10. Pmjected Point Source Emissions (tons) .................................................................... 38 

Table 3-11. Projected Nonpoint Source Emissions (tons) .............................................................. 39 

Table 3-12. Largest Nonpoint PM2.5 Emissions by Source Classification, Year 2024 ................. 39 

Table 3-13. Projected Onroad Mobile Source Emissions (tons) .................................................. .40 

Table 3-14. Projected Nonroad Mobile Source Emissions (tons) .................................................. 41 

Table 3-15. Projected Emissions- Total of All Sectors (tons) ....................................................... 42 

Table 3-16. Emissions Decrease ....................................................................................................... 43 

Table 4-1. 2024 Motor Vehicle Emissions, Emissions Budgets, and Safety Margins .................. 50 

Table 5-1. Summary of Projected S02 Emissions- Total of All Sectors (tons) ........................... 51 

Table 5-2. Summary of Projected NOx Emissions- Total of All Sectors (tons) ........................... 52 

Table 5-3. Summary of Projected PM2.5 Emissions- Total of All Sectors (tons) ........................ 52 

VI 
Atlanta PM2.5 Nonattainment Area 

Redesignation Request and Maintenance Plan 

LIST of APPENDICES 

Appendix A Source Appmtionment of PM2.5 in Georgia 

Appendix B Georgia's Basic Smoke Management Plan and Memorandnm of Understanding 

Appendix C EPD's Methodology for Emissions Projections [including interpolation calculations] 

Appendix C-1 EGU Control Schedules and Efficiencies -Atlanta NAA 

Appendix C-2 Summaty ofEGAS Derived SCC-Specific Growth Factors 

Appendix C-3 Summaty Emissions Inventoty for the Atlanta PM25 Nonattainment Area 

Appendix C-4 Analysis ofNomoad Emissions 

Appendix C-5 Nonroad Growth Factors and SEMAP Rail and CMV Factors 

Appendix C-6 Aircraft and Locomotive SCC-Specific Emissions, Growth and Control Factors 

Appendix C-7 MOVES Inputs, Documentation, and Outputs 

vii 
Acronym 

AEO 

AERR 

AIRS 

AQS 

ARC 

CAA 

CAIR 

CARB 

CERR 

CFR 

co 

CSAPR 

DNR 

DOT 

EGAS 

EGU 

EPA 

EPD 

Atlanta PM2.s NonattainmentArea 

Redesignation Request and Maintenance Plan 

List of Acronyms 

Meaning Acronym Meaning 

Annual Energy Outlook ERTAC Eastern Regional Technical Advisory 

Committee 

Annual Emissions Repmting FGD Flue Gas Desulfmization 

Requirements 

Aerometric Information FR Federal Register 

Retrieval System 

Air Quality Subsystem FRM Federal Reference Method 

Atlanta Regional Commission GDOT Georgia Department of Transportation 

Clean Air Act GFC Georgia Forestly Commission 

Clean Air Interstate Rule HC Hydrocarbon 

California Air Resources Board HPMS Highway Performance Monitoring 

System 

Consolidated Emissions ICI Industrial and Commercial!Instit!Jtional 

Repmting Rule 

Code of Federal Regulations MOU Memorandum of Understanding 

Carbon Monoxide MOVES Motor Vehicle Emissions Simulator 

Cross-state Air Pollution Rule MPO Metropolitan Planning Organization 

Department ofNatural MVEB Motor Vehicle Emissions Budget 

Resources 

Depmtment ofTransportation MWe Megawatt Electrical 

Economic Growth Analysis MWh Megawatt Hours 

System 

Electric Generating Unit NAA N onattainment Area 

Environmental Protection NAAQS National Ambient Air Quality Standard 

Agency 

Environmental Protection NCD NMIM County Database 

Division 

viii 
Acronym 

NEI 

NMIM 

NTE 

NOx 

OAQPS 

PM 

PM2.s 

PMF 

Ppm 

RACM 

RACT 

RFP 

sec 

Atlanta PM2.s Nonattainment Area 

Redesignation Request and Maintenance Plan 

Meaning Acronym Meaning 

National Emissions Inventory SCR Selective Catalytic Reduction 

National Mobile Inventory SEMAP Southeastern Modeling Analysis Plan 

Model 

Not-To-Exceed SIP State Implementation Plan 

Nitrogen Oxides SMP Smoke Management Plan 

Office of Air Quality so2 Sulfur Dioxide 

Planning and Standards 

Patticulate Matter SOA Secondmy Organic Aerosols 

Fine Pmticulate Matter STN Speciated Trends Network 

Positive Matrix Factorization tpy tons per year 

pmts per million suv Spmt Utility Vehicle 

Reasonably Available Control ULSD Ultra-Low Sulfur Diesel 

Measures 

Reasonably Available Control VISTAS Visibility Improvement State and Tribal 

Technology Association of the Southeast 

Reasonable Further Progress VMT Vehicle Miles Traveled 

Source Classification Code WRD Wildlife Resources Division 

IX 
1.0 Introduction 

Atlanta PM2.s NonattainmentArea 

Redesignation Request and Maintenance Plan 

This document contains the technical support for the Georgia Environmental Protection Division's 

(EPD's) request that the Atlanta nonattaimnent area be redesignated as an area attaining the 1997 

annual fine pmiiculate matter (PM2.5) National Ambient Air Quality Standard (NAAQS) pursuant to 

Sections I 07(d)(3)(D) and (E) of the Clean Air Act (CAA), as amended. This redesignation request 

was prepared in accordance with U.S. EPA Guidance issued in 1992 (memorandum dated September 

4 of that year fi·om John Calcagni1

). 

1.1 Nonattainment Designation and Attainment Demonstration 

In 2005, EPA designated four PM2.s nonattainment areas in Georgia: Atlanta, Chattanooga (which 

also includes pmis of Alabama and Tennessee), Floyd County, and Macon. Figure 1-1 shows their 

locations. The Atlanta nonattainment area is located in the nmihwest quadrant of the state and is 

comprised of twenty whole counties and two partial counties: Barrow, Batiow, Carroll, Cherokee, 

Clayton, Cobb, Coweta, DeKalb, Douglas, Fayette, Forsyth, Fulton, Gwinnett, Hall, Henry, Newton, 

Paulding, Rockdale, Spalding, Walton, Heard (paiiial), and Putnam (partial) [reference 70FR965]. 

1 "Procedures for Processing Requests to Redesignate Areas to Attainment", September 4, 1992, Jolm 

Calcagni, Director, Air Quality Management Division, OAQPS, USEPA. 

1 of 54 
Atlanta PM2.5 Nonattainment Area 

Redesignation Request and Maintenance Plan 

Figure 1-1. PM2.5 Nonattainment Areas in Georgia 

The part of Heard County included in the nonattainment area is the northeast pmtion that extends 

north of 33 degrees 24 minutes (nmth) to the Carroll county border and east of 85 degrees 33 

minutes (west) to the Coweta County border. The part of Putnam County included in the 

nonattainment area is the area described by U.S. Census 2000 block group identifier 13-237-9603-1. 

Coal-fired electric generating units are located in both of the pattial counties. 

EPA made initial designations of nonattainment areas, including the Atlanta nonattainment area, for 

the 1997 annual PM25 NAAQS on January 5, 2005 (70FR944), and amended the designations on 

AprilS, 2005 (70FR19844). 2001-2003 PM25 design values exceeded the standard at seven of nine 

monitoring sites located within the boundaries of the nonattainment area. The highest design value 

was 18.0 ~tg/m3 at the Fire Station No. 8 monitor located in Fulton Com1ty. The observed PM2_5 

design values at Atlanta's nonattainment area monitors violated the annual standard, as shown in 

Table 1-1 below. 

2 of 54 
I 

I 

I 

I 

Atlanta PM2.s NonattainmentArea 

Redesignation Request and Maintenance Plan 

Table 1-1. PM2.s Design Values for Atlanta Area Monitors 2001-2003 

~····;~~~j;;,:r:: ii ..·.•········• 

)·····(. ..·.·······<···········.··············.' 

..... ·····~;,\ ·Jti •. 

}·\••··•··••··. ~.r' ..... ···<.i 

/.<' '' .···;·.·; t >. 

i t . .. ...... •.• \ > .. i ~1\ii{P~sJ~~~~Iqe .. · 

{. zM.i-.fQO~ :CilM\i~) 

Forest Park-Georgia 13-063-0091 Clayton 16.1 

DOT 

Kennesaw-National 13-067-0003 Cobb 16.1 

Guard 

Powder Springs- 13-067-0004 Cobb NA 

Macland Aquatic 

Center 

South DeKalb I 13-089-0002 I DeKalb I 15.7 

Doraville 13-089-2001 DeKalb 16.1 

E. Rivers School 13-121-0032 Fulton 16.3 

Fire Station No. 8 13-121-0039 Fulton 18.0 

Georgia Tech I 13-121-0048 I Fulton I NA* 

Gwinnett Tech I 13-135-0002 I Gwinnett I 15.6 

Gainesville-Fair Street 13-139-0003 Hall 14.9 

School 

Yorkville I 13-223-0003 I Paulding I 14.1 

* The Georgia Tech monitor began operation in 2006 and stopped operation in 2008. 

The State of Georgia prepared and submitted a PM25 attainment demonstration plan for the Atlanta 

Nonattainment At'ea to EPA Region 4 on July 6, 2010 (cover date is May 24, 2010). The plan was 

based on modeling of the effects of existing and planned control measures on air quality in the 

Atlanta area and demonstrated attainment ofthe standard by AprilS, 2010. 

Since EPA has determined that the area has met the clean data requirements and attained the standard 

prior to the attainment date (76FR 76620), the SIP requirements that the July 6, 2010 attainment 

demonstration was required to fulfill are suspended. The attainment demonstration plan has been 

withdrawn and 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 requirements upon clean data detennination is specified in 40 CPR I 004( c) and also in a 

December 14, 2004 memo from Stephen D. Page of U.S. EPA. 

3 of 54 

I 

I 

I 

I 
Atlanta PM2.s Nonattainment Area 

Redesignation Request and Maintenance Plan 

1.2 RedesignationRequfSt 

This document contains Georgia's request that the Atlanta nonattaimnent area be redesignated to 

attaimnent with respect to the annual NAAQS for PM25 (1997 fine pmticulate matter standard, 

retained in 2006). Section 107(d) of the CAA states that an area can be redesignated to attainment if 

the following conditions are met: 

1. The EPA has dete~mined that the NAAQS has been attained. 

2. The applicable implementation plan has been fully approved by EPA under Section llO(k). 

3. The EPA has dete1mined that the improvement in air quality is due to pennanent and 

enforceable reductions in emissions. 

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

5. The EPA has fully approved a maintenance plan, including a contingency plan, for the area 

as required by CAA Section 175A. 

The suppmting 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. 

13 MaintenancePlan 

The maintenance plan (see above) has two required components 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/ the Atlanta area PM25 maintenance plm1 also includes the following elements: 

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

• A commitment to continued operation of ambient monitoring 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 

4 of 54 
Atlanta PM2.

5 NonattainmentArea 

Redesignation Request and Maintenance Plan 

2.0 Redesignation Request 

As noted in Section 1.2 of this document, Section 107(d) of the CAA states that an area can be 

redesignated to attainment if the following conditions are met: 

1. The EPA has determined that the NAAQS has been attained. 

2. The applicable implementation plan has been fully approved by EPA under Section llO(k). 

3. The EPA has determined that the improvement in air quality is due to permanent and 

enforceable reductions in emissions. 

4. The state has met all applicable requirements for the area under Section 110 and Patt D. 

5. The EPA has fully approved a maintenance plan, including a contingency plan, for the area 

under CAA Section 175A. 

This section of the document includes supporting documentation for the following: 

• Attainment of the annual PM25 NAAQS based on ambient data from 2008 through 2010; 

• Approval by EPA of the implementation plan under Section llO(k); 

• Improvement of air quality with respect to PM25 is due to permanent and enforceable 

reductions in emissions; and 

• The state has met all applicable requirements for the area under Section 110 and Patt D. 

2.1 Attainment of the Annual PM2.5 NAAQS 

A monitoring site is in attainment of the annual PM25 standard when the annual standard design 

value is less than or equal to 15.0 micrograms per cubic meter (f1g/m3

) 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-quatter averages. The data must be complete and qualityassured, consistent with 40 CFR Part 58 requirements 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 standard. For a nonattainment area to achieve 

attainment, all monitoring sites in the nonattainment area must be in attainment. 

The Atlanta area design values, based on data from 2008 through 20 I 0 for each monitor, are less 

than 15.0 ftg/m3

, which demonstrates attainment of the standard. The monitoring network and 

ambient PM25 data are presented below. 

2.1.1 Monitoring Network 

There are currently ten active ambient PM25 FRM monitoring sites in the Atlanta nonattainment 

area, as shown in Table 2-1 and Figure 2-1. Providing adequate coverage of the nonattainment area, 

data from.these sites represent a neighborhood scale, which extends up to 4.0 kilometers from each 

monitor. The sites are considered to be patt of the State and Local Air Monitoring Stations (SLAMS) 

monitoring network, with the monitoring objective of sampling for population exposure. The FRM 

monitors were installed in accordance with 40 CFR 58. 

The Fire Station No.8 (13-121-0039) PM2.

5 FRM sampler, located in Fulton County, ran every three 

days fi·om 1121199 to 9/29/06. The sampler was shut down due to the potential effects of building 

ventilation stacks (used for fire engine exhaust) on measured PM25 levels and the proximity of trees 

to the monitor, which violated siting criteria. The Georgia Tech sampler (13-121-0048) ratl from 

5 of 54 
Atlanta PM2.s Nonattainment Area 

Redesignation Request and Maintenance Plan 

9/26/06 until 12/29/08 as an additional urban site until it was decided that the Fire Station No. 8 

sampler would meet siting criteria if it were moved 20 feet from its original location. The Fire 

Station No.8 sampler was restarted on 12/2/08. 

One Speciated Trends Network (STN) monitor is located at the South DeKalb site (13-089-0002). 

The STN monitor has been collecting data since March 2, 2001. The sampling schedule of the STN 

monitor began as eveJy six days and ran on that schedule until March 26, 2001, when it changed to 

eve~y three days. 

-~ \ 

\ 

\. . ' 

·••••· Jiilvilkioso.,.ooo1 \ \::;o·t._~--- \... _/\ 

*Note the Floyd County and Clarke County monitors are not in the Atlanta Nonattainmcnt Area. 

Figure 2-1. Locations of Atlanta Area PM2,5 Sampling Sites. 

6 of 54 
.. ··· .. ;>• L; . <:·:. 

r.< ........ ••• ••• •••••• 

Site Name, 

! .... 

. . ···. 

· ... ·· ..... ·.··· ii •• •••••••••••••••••••• •• 

F ores! Park -Georgia 

DOT 

Kennesaw-National 

Guard 

Powder SpringsMacland Aquatic 

Center 

South DeKalb 

Doraville 

E. Rivers School 

Fire Station No. 8 

Georgia Tech 

Gwinnett Tech 

Gainesville-Fair 

Street School 

Yorkville 

Atlanta PM2.s Nonattainment Area 

Redesignation Request and Maintenance Plan 

Table 2-1. Atlanta Area PM2.s Data Collection Sites 

J < •• 

! ················i······· /i 

I>····· \•.'> .... . i .. ··· ...... ·.······· . .. ·.····· ..... · 

.. 

••••••••••••••••• • • •• •• ••••••• •• •• ••• ••••• •• • 

.... ·. 

.. ·,.,· .. 

Start Date"" ]!;n~J)at~ • l lifA<t:Dilte c: AQSc · <;ou~fY· FRMData· FRMData . • Specj~tioJ1 Data SitelD ... ,· .· .'· ..... ···· 

1 

ColJec!ioJi . Collection · · Collection 

I • •.. • •·-··.;.··•••·.::. ·.·.·• ·.·••··•· ,> 

!: . . • .. · •...• .. .··· .. ·······.'··.· . . . ········· . . . '· . · .. ·· 

13-063-0091 Clayton January 9, 1999 

13-067-0003 Cobb February 7, 1999 

13-067-0004 Cobb 

February 5, 2003 

13-089-0002 Dekalb January 22, 1999 October 1, 2000 

13-089-2001 Dekalb January 1, 1999 

13-121-0032 Fulton January 1, 1999 

13-121-0039 Fulton January 21, 1999 

Stopped on 

September 30, 2006 

Restarted on 

December 2, 2008 

13-121-0048 Fulton September 26, 2006 December 

29,2008 

13-135-0002 Gwinnett January 1, 2000 

13-139-0003 Hall February 14, 1999 

13-223-0003 Paulding January24, 1999 

*EPA's Air Quality System 

7 of 54 

·... . .•· ..~n\! · ... , Date., 

Spedaii 

on Data 

Colledi 

• t:ln ·····•;·; ·.· . 
Atlanta PM2.s Nonattainment Area 

Redesignation Request and Maintenance Plan 

2.1.2 Ambient PM2•5 Data 

Table 2-2 shows the annual average PM2.5 concentrations and the associated 3-year average that 

demonstrate attainment of the standard in the Atlanta area. The 2008-2010, 3-year design values for 

each monitor are below the standard of 15.0 J.lg/m3

. The table includes annual averages from 2003 

through 2010, demonstrating the downward trend in the measured ambient PM25 level in the 

nonattainment area. The concentrations provided in Table 2-2 for 2010 for each monitor show 

continued evidence that the area is meeting the standard. To date, the quality-assured annual 

averages for 2011 are not available. 

Table 2-2. Annual and 3-year Average Ambient PM2.

5 Concentrations 

Forest Park-Georgia DOT 

(13-063-0091) 

Kennesaw-National Guard 

(13-067-0003) 

Powder Springs-Macland 

Aquatic Center (13-067-

0004) 

South DeKalb (13-089-0002) 

Doraville (13-089-2001) 

E. Rivers School (13-121-

0032) 

Fire Station No. 8 (13-121-

0039) 

Georgia Tech (13-121-0048)* 

Gwinnett Tech (13-135-0002) 

Gainesville-Fair Street 

School (13-139-0003) 

Yorkville (13-223-0003) 

16.0 

16.0 

15.2 

15.0 

15.4 

16.1 

17.7 

16.2 

14.7 

13.8 

16.8 16.6 

15.8 16.3 

15.2 15.5 

16.1 15.5 

15.5 15.8 

16.1 15.9 

17.6 17.0 

16.1 16.1 

14.0 14.5 

13.4 14.6 

16.7 15.3 13.7 

16.5 15.3 13.5 

15.8 14.5 13.1 

15.4 14.8 12.7 

14.5 15.1 13.1 

15.4 15.7 13.0 

18.4 7.6 

15.1 15.5 14.3 

16.9 14.2 12.4 

13.8 13.4 ll.8 

13.9 14.3 11.9 

•The Georgta Tech momtor stopped operatiOn on December 29, 2008. 

8 of 54 

ll.5 13.4 12.9 

11.2 12.2 12.3 

10.3 12.1 11.9 

11.4 12.3 12.1 

11.7 12.2 12.3 

11.6 12.2 12.3 

12.1 14.5 11.4 

11.6 12.3 12.1 

10.2 11.4 11.2 

9.9 11.2 11.0 

N/A 

N/A 

12.3 

N/A 

N/A 

13.0 

13.6 

12.5 

11.9 

11.6 
Atlanta PM2.s NonattainmentArea 

Redesignation Request and Maintenance Plan 

Because of data completeness issues at the Powder Springs, E. Rivers School, Fire Station 

#8/Georgia Tech, Gwinnett Tech, and Yorkville monitors for the 2007-2009 and 2008-20 I 0 periods. 

EPA performed a qumierly maximum data substitution test using 40 CFR Pmi 50 Appendix N and 

the April 1999 Guideline on Data Handling Conventions for the PM NAAQS. 

The Fire Station #8 monitor was relocated to the Georgia Tech campus and was assigned a separate 

AQS number. It was moved back to Fire Station #8 at the end of 2008 and resumed normal 

operation. There were no data completeness issues at either site during the times each site was 

operated. Further information on the data substitution used for the Atlanta area monitors can be 

found in the September 14, 2011, Federal Register notice (76 FR56701) and its cmresponding 

Technical Support Document. 

2.1.3 Clean Data Determination 

On December 8, 2011, EPA promulgated its determination (76 FR 76620) that the Atlanta 

nonattaimnent area had attained the 1997 annual average PM25 National Ambient Air Quality 

Standard (NAAQS). This determination was based upon quality-assured and certified ambient air 

monitoring data for the 2008-2010 period that showed design values below 15.0 f1g/m3 as indicated 

in Table 2-2. With the clean data determination, EPA suspended the requirements for the 

nonattainment area to submit an attainment demonstration, a reasonable further progress (RFP) plan, 

associated RACM and contingency measures. These requirements are suspended as long as the area 

continues to attain the standard. This final rule became effective on January 9, 2012. 

2.2 ImplementationPian UnderSectionllO(k) 

Section II O(k) of the CAA addresses EPA's actions on 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 I I O(k), and must satisfY all requirements 

that apply to the area. It should be noted that approval action on SIP elements and the redesignation 

request may occur simultaneously." 

The State of Georgia has prepared and submitted a PM25 attainment demonstration plan for the 

Atlanta Nonattainment Area. The plan was submitted for approval to EPA Region 4 on July 6, 2010. 

As discussed in Section I .2 of this redesignation request and maintenance plan, the attainment 

demonstration, RFP, associated RACM, and contingency requirements that the July 6, 20 I 0 SIP 

revision was required to fulfill have been suspended. Therefore, the attainment demonstration has 

been withdrawn and substituted with submittal of this maintenance plan. There are no longer any 

Section 11 O(k) requirements to be met. 

2.3 Permanent and Enforceable, and Other Reductions in Emissions 

In order for the nonattainment area to be redesignated to attainment, the State must demonstrate (and 

EPA must determine) that the improvement of aJUbient PM2.5 concentrations during the years 2008 

through 2010 is due to permanent and enforceable reductions in emissions that were implemented 

following the nona!tainment design value period (2001-2003). This subsection contains Georgia 

EPD's demonstration that the improved air quality is due to permanent and enforceable emissions 

reductions. The elements of the demonstration described below are as follows: 

9 of 54 
Atlanta PM2.s Nonattainment Area 

Redesignation Request and Maintenance Plan 

• Source appmtionment, which links individual, observed ambient PM25 species to 

specific emissions sources; 

• State control measures and associated emissions reductions; 

• Federal control measures and associated emissions reductions; and 

• Reductions in S02 emissions from upwind states. 

2.3.1 Source Apportionment of Ambient PM2.

5 

Source apportionment of speciated ambient pollutant measurements is an impmtant tool for the 

prioritization of pollutant control strategies. Presented here are source-apportionment results for 

2003-2004 speciated PM25 measurements in the Atlanta, Floyd County, and Macon areas (Figure 2-2 

and Table 2-3). The source-apportionment results are based on Positive Matrix Factorization (PMF), 

a factor analytic method that distinguishes correlation patterns among speciated PM2.

5 measurements 

in a given location. More detailed information on source apportionment is presented in Appendix A. 

The similarities between the PMF results for the three sites show the regional nature of PM25 . The 

major impacting factors at all sites are secondary sulfates, secondary organic aerosols (SOA), mobile 

sources, and biomass buming. The Atlanta area, as expected, has higher levels of mobile-source 

PM2.

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 exhibits a relatively high contribution of Lime/Minerals 

PM2.5. This is likely due to local sources in the industrial area where the site is located. 

12.0 

"' 10.0 

.§ 

Cl 

" 8.0 

6.0 

4.0 

2.0 

0.0 

Atlanta Floyd county Macon 

II Unspec. 

I!!ISOA 

D Sec. Nitrate 

ill Sec. Sulfate 

II Zn-rich 

Figure 2-2: Average factor contributions for 2003-04 at the Atlanta, Floyd County, and 

Macon STN sites using PMF 

10 of 54 
Atlanta PM2.s NonattainmentArea 

Redesignation Request and Maintenance Plan 

These results are useful for an assessment of control strategies. Secondary sulfate makes up 

approximately five pg/m3 (32%) of ambient PM25, 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. Contributions from all other source-categories were small in 

general, though the Macon and Rome sites seem to be affected by local sources related to 

lime/minerals processing and soil dust re-suspension. 

Secondmy sulfates are fmmed in the atmosphere from S02 emissions. As the sulfate fraction is the 

largest fraction of ambient PM25, it is evident that controlling S02 emissions (generated primarily by 

coal-burning EGUs) would reduce PM25 levels throughout the state. Secondary nitrates are 

associated with NOx emissions Jiom 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 control biogenic emissions. Biomass burning generates 

elemental carbon (soot) and is associated with wildfires, prescribed buming, and wood-fired boilers. 

In addition to NOx. mobile sources generate elemental carbon. 

Table 2-3. Average factor contributions to PM2.

5 (llg/ m 3

) for 2003-04 at the Atlanta, 

Floyd County, and Macon STN sites using PMF 

Factor Atlanta Floyd Connty 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 buming 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 

11 of 54 
Atlanta PM2.s NonattainmentArea 

Redesignation Request and Maintenance Plan 

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, biomass burning, and mobile sources. Control of 

S02 is the most impmiant component of the strategy, as seconda1y sulfates make up the largest 

controllable contribution to ambient PM25. State measures that target reduction of these emissions 

are: 

• S02 and NOx controls on EGUs- Georgia Rule (sss); 

• S02 limits on EGUs- Georgia Rule (uuu); and 

• The Smoke Management Plan. 

Table 2-4 shows the timetable of implementation of these measures as well as the species controlled 

by each measure. The con-elation between the drop in PM25 annual averages and the implementation 

of the control measures, pmticularly Georgia Rule 391-3 -l-.02(2)(sss ), lends strong evidence that the 

improvements in air quality are a result of reduction in emissions and not a meteorologicallyinfluenced phenomenon. Detailed discussions of the measures are presented in the following 

subsections. 

12 of 54 
Atlanta PM2.5 Nonattainment Area 

Redesignation Request and Maintenance Plan 

Table 2-4. Timetable of State Measure Implementation 

~. 3 

PMz.s ann. avg. ()lg/m ), 2003 2004 2005 2006 2007 2008 

Atlanta Area Mo11itors . 

Forest Park'Georgia DOT 16.0 16.8 16.6 16.7 15.3 13.7 (13-063-0091) 

Kennesaw-National Guard 16.0 15.8 16.3 16.5 15.3 13.5 (13-067-0003) 

Powder Springs-Macland 15.2 15.2 15.5 15.8 14.5 13.1 Aquatic Center ( 13,067,0004) 

South DeKalb (13-089-0002) 15.0 16.1 15.5 15.4 14.8 12.7 . ··. ·. 

Doraville (13-089-2001) 15.4 15.5 15.8 14.5 15.1 13.1 

E. Rivers School (13-121- 16.1 16.1 15.9 15.4 15.7 13.0 0032) . 

. .. 

Fire Station No.8 (13-121- 17.7 17.6 17.0 18.4 -- 7.6 0039) 

-. Georgia Tech (13-121-0048)* -- -- -- 15.1 15.5 14.3 

Gwinnett Tech (13-135-0002) 16.2 16.1 16.1 16.9 14.2 12.4 

Gainesville-Fair Street School 14.7 14.0 14.5 13.8 13.4 Jl.8 (13-139-0003) 

Yorkville (13-223-0003) 13.8 13.4 14.6 13.9 14.3 11.9 ~ . 

,;· . .·······~·· . .. •· .. .·· ···.· · .....•.. 

2003 l';oo4i .. z«ir{ 2()1!6 liQ!J? I zoo$ Y•~a""'~ .. ~ );_;, ~· 

•••••••••• 

·.· ·.· . . .•........ ·····• ... . .....•.... · · .. ·.· ... ••• ••••••••••••• 

, ................ · 

~·.·· ... · ..•..•.... _ ...... ·· .. 

·-· . . 

Georgia Rule ( sss) S02,N0x 

Georgia Rule (mm) so2 

2009 2010 

Jl.5 13.4 

11.2 12.2 

10.3 12.1 

11.4 12.3 

11.7 12.2 

11.6 12.2 

12.1 14.5 

-- --

11.6 12.3 

10.2 11.4 

9.9 11.2 

2iJo9 1;9W 

•. > I ••.••••..••••• • •••.•• -••.• ·•·• • • •• 

~ 

Smoke Management Plan PM, NO, 

*The Georgia Tech monitor stopped operation on December 29, 2008. -· 

**Controls were required on December 31, 2008, but were actually sta1ted up in the first half ofthe year. 

13 of 54 
Atlanta PM2.5 Nonattainment Area 

Redesignation Request and Maintenance Plan 

2.3.2.1 S02 and NOx Controls and S02 Limits 

Atmospheric secondary sulfate is formed from emissions of S02• Coal-fired EGUs are by far the 

most significant source of S02 emissions in Georgia and in the Southeast. Georgia's Multipollutant 

Rule [391-3-l-.02(2)(sss)]requires flue gas desulfurization (FGD) and selective catalytic reduction 

(SCR) controls on the majority of coal-fired EGUs in Georgia. This state-enforceable rule was 

promulgated in 2007 for the purposes of lowering ozone and PM25 concentrations by controlling 

precursor emissions and for reducing mercury deposition. The FGD controls reduced S02 emissions 

rates from the affected emissions units by at least 95 percent and the SCR controls reduced NOx 

emissions rates by approximately 85 percent. The S02 and NOx controls were required in suppmt of 

EPA's CAIR rule, which was promulgated in 2005 and required statewide caps for NOx and S02 

beginning in 2009 and 2010, respectively. The CAIRrule is discussed fmther in Section2.3.3. 

Georgia Rule (uuu), S02 Emissions from Electric Utility Steam Generating Units, is a companion 

rule to Rule (sss) and is both state and federally enforceable upon approval by EPA. Both of these 

rules were implemented in response to CAIR and require emissions reductions consistent with 

CAIR's original schedule slatting in 2009. The rule requires 95% reduction of S02 emissions from 

the majority of Georgia's coal-fired EGUs, with the requirement being phased in from 2010 through 

2016. It requires 95% reduction of S02 emissions from three of the four EGUs at Plant Bowen by 

January I, 2010, and the fourth unit by January I, 2012, on both coal-fired EGUs at Plant Wansley 

by January 1, 2010, and both EGUs at Plant McDonough in 2012, and at the two largest EGUs at 

Plant Yates by 2015.3 

It has been well demonstrated that ambient secondary sulfate in a given location can be significantly 

affected by S02 emissions from distant sources. Therefore, secondmy sulfate in the Atlanta Area is 

due not only to S02 emissions from Plant Yates, Plant Wansley, and Plant Bowen, located inside the 

nonattainment area, but also to S02 emissions from other coal-fired EGUs in north Georgia. Plant 

McDonough has been completely converted to a combined cycle combustion turbine facility and is 

no longer a coal-fired facility. 

Figure 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 

was a close second to Plant Scherer in energy production and historically has been by far the highest 

S02-emitting facility in the state. Plant Scheret; which was first in Georgia in energy production, is 

located approximately 20 miles from the Atlanta nonattainment area. The facilities shown in the 

figure comprise seven of the ten coal-fired EGU facilities that were operated in Georgia in 2007. In 

2007, the energy produced by the seven facilities made up 97 percent of the statewide energy 

production from coal-fired facilities. 

3 One of the smaller EGUs at Plant Yates has an existing S02 scrubber that was required to achieve 90% S02 

reduction by January I, 2010. 

14 of 54 
Tennessee 

Alabama 

I 

Atlanta PM2.s Nonattainment Area 

Redesignation Request and Maintenance Plan 

N. Carolina 

S.Carolina 

Figure 2-3. Locations and 2007 Energy Production of Coal-fil'ed EGU Facilities 

in North Georgia 

15 of 54 
Atlanta PM2.s Nonattainment Area 

Redesignation Request and Maintenance Plan 

SCR Controls Required by Rule (sss) 

Rule (sss) requires SCR controls to be operated year-round, starting with six EGUs in 2008 and 

2009. Of these six units, which include Bowen Units 2, 3, and 4; Wansley Units I and 2; and 

Hammond Unit 4; Bowen and Wansley's units are located in the Atlanta nonattailUllent area. 

The schedule for the operation of SCRs on the remaining EGUs in the Atlanta NAA is as follows: 

• Bowen Unit 1 has been required to operate an SCR year-round siuce June 2010. 

• McDonough Unit 2 was required to operate an SCR year-round beginning in December 

2011; however, the facility has been completely converted to a combined-cycle combustion 

turbine facility and is no longer a coal-fired facility. 

• McDonough Unit I was required to operate an SCR year-round beginning in April 2012; 

however, the facility has been completely converted to a combined-cycle combustion turbine 

facility and is no longer a coal-fired facility. 

• Plant Yates Units 6 and 7 are required to operate an SCR year-round beginning in June of 

2015. 

• Beginning in Januaty of2018, the remaining Units 2 through 5 at Plant Yates are required to 

be evaluated for additional mercury controls if the total annual heat input of those units 

combined exceeds 33,608,398 million Btu. Any additional required controls could 

contribute to reduced NOx and S02 emissions. 

Bowen Units 1, 2, 3, and 4; Wansley Units 1 and 2; and Hammond Unit 4 have NOx controls that 

were already in place and operating during the ozone control season by the end of 2003. The Title V 

permit of each of these facilities has been amended to permit operation of the FGD and SCR 

controls. 

FGD Controls Required by Rule (sss) 

The required FGD control implementation date varies by EGU, starting on December 31, 2008. S02 

controls were actually started on five units in May 2008. S02 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. 

S02 controls on a third unit at Plant Bowen and the second unit at Plant Wansley began operation on 

April 1, 2009. 

Table 2-5 shows the annual S02 emissions for the coal-fired facilities in north Georgia for the period 

2003 through 2010. 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 fonn in Figure 2-4. 

16 of 54 
Atlanta PM2.s NonattainmentArea 

Redesignation Request and Maintenance Plan 

Comparing 2003 to 2010, S02 emissions were reduced by 60.2 percent while generation was down 

only by 4. 7 percent. These statistics provide clear evidence that the reduction in PM2.s concentration 

is due to permanent and enforceable controls rather than to reduced generation. 

17 of 54 
Hammond 

Bowen 

Branch 

McDonough 

Scherer 

Wansley** 

Yates 

Atlanta PM2.s NonattainmentArea 

Redesignation Request and Maintenance Plan 

Table 2-5. Annual S02 Emissions and Generation (106 MWh) from North Georgia 

Coal-fired EGU Facilities, 2003- 2010 

so, (tpy) 35,900 37,700 39,500 40,600 47,800 12,500* 900* 2,427 

generation 4.79 4.11 4.64 4.27 5.09 4.32 3.73 3.23 

so, (tpy) 164,900 165,900 186,500 206,400 196,800 148,100* 54,800* 7,618 

generation 21.9 21.9 23.3 23.7 24.0 23.4 22.9 24.7 

so, (tpy) 64,800 70, I 00 90,500 96,000 98,400 94,000 60,100 53,258 

generation 8.28 7.97 10.3 10.8 10.9 10.7 6.82 6.09 

so, (tpy) 23,900 22,700 27,700 28,800 28,500 24,300 15,900 17,115 

generation 3.75 3.52 3.92 4.07 4.07 3.43 2.34 2.28 

so, (tpy) 83,900 79,700 82,900 74,200 76,500 77,700 69,500 69,862 

generation 21.3 24.6 25.5 24.5 26.5 25.7 24.3 24.5 

so, (tpy) 94,000 99,000 101,500 96200 93,900 74,300* 7400* 2,343 

generation 13.7 14 15.1 14.8 16.1 15.5 11.8 9.79 

so, (tpy) 44,900 50,600 66,500 75,500 77,200 68,200 45,500 54,256 

generation 6.73 6.22 7.37 7.49 8.10 7.37 4.90 6.06 

TOTAL S02 Tons/yr 512,300 525,700 595,100 617,700 619,100 499,100 254,100 203,879 

TOTAL Generation 106 MWh 80.45 82.32 90.13 89.6 94.76 90,42 76.79 76.65 

Continued, next page. 

18 of 54 
· .. ,,..... :··· . f1VI;.s ~~~~-. l1Y!:·.(f1g/m3), .. • At!~nta Area .Monitors . · ----'.;-_:-:_ ·_;--o:--_-/-__ ,, . :.,::. -'/_,_:-:-:>:----::f_;: ___ :_. 

Forest Park-Georgia DOT 

(13-063-0091) 

Kennesaw-National Guard 

(13-067-0003) 

Powder Springs-Macland 

Aquatic Center 

(13-067-0004) 

South DeKalb (13-089-0002) 

Doraville (13-089-2001) 

E. Rivers School 

(13-121-0032) 

Fire Station No. 8 

(13-121-0039) 

Georgia Tech (13-121-0048) 

Gwinnett Tech 

(13-135-0002) 

Gainesville-Fair Street 

School (13-139-0003) 

Yorkville (13-223-0003) 

Atlanta PM2.5 NonattainmentArea 

Redesignation Request and Maintenance Plan 

· .. · .. •··· .. I2~~;L· . 20()4 ·.·.·.·••·· 2pos·· .... •·•••·••• 

.• 2007 

!··.·· ...•.••••..••.•. < 2006······················ ••. '.i•~.- < 

.·· .. , .. 

.......... ··.·.··· • ••••••••••••••••• • '( . .. ···•····.· ... ······ ... 

16.0 16.8 16.6 16.7 15.3 

16.0 15.8 16.3 16.5 15.3 

15.2 15.2 15.5 15.8 14.5 

15.0 16.1 15.5 15.4 14.8 

15.4 15.5 15.8 14.5 15.1 

16.1 16.1 15.9 15.4 15.7 

17.7 17.6 17.0 18.4 --

-- -- -- 15.1 15.5 

16.2 16.1 16.1 16.9 14.2 

14.7 14.0 14.5 13.8 13.4 

13.8 13.4 14.6 13.9 14.3 

Source: EPA Clean Air Markets DIVISIOn 

2008 

.t . . ..· · .. 

13.7 

13.5 

13.1 

12.7 

13.1 

13.0 

7.6 

14.3 

12.4 

11.8 

11.9 

* S02 control, required by Georgia Rule (sss), was operational on one or more EGUs for partial or full year 

**Does not include emissions from facility 1s gas-fired units 

19 of 54 

zoq9 •. .. 2010 . 

. • i; . \ ..... · 

11.5 13.4 

11.2 12.2 

10.3 12.1 

11.4 12.3 

11.7 12.2 

11.6 12.2 

12.1 14.5 

-- --

11.6 12.3 

10.2 11.4 

9.9 11.2 
700000 

600000 

500000 

400000 

300000 

200000 

100000 

0 <:') 

0 

0 

N 

Atlanta PM2.5 Nonattainment Area 

Redesignation Request and Maintenance Phm 

100 

90 

80 

70 

60 

50 lliiiiiii!IS02 (tpy) 

40 -+-gen (million MWh) 

30 

20 

10 

0 

" 10 <D ,..__ co (J) 0 

0 0 0 0 0 0 ~ 

0 0 0 0 0 0 0 

N N N N N N N 

Figure 2-4. S02 Emissions and Generation from North Georgia 

Coal-fired EGU Facilities, 2003 - 2010 

2.3.2.2 Smoke Management Plan 

Foreshy and agriculture, two of the Georgia's most significant industries, utilize prescribed burning 

practices to suppmt production. Prescribed burning is the controlled application of fire to existing 

vegetative fuels to accomplish planned land management objectives or to mitigate catastrophic 

wildfires. In addition to managing forests and agricultural resources, prescribed burning helps 

protect lives and property by reducing accumulations of forest fuels and helps to sustain imperiled 

species and ecosystems. The Georgia General Assembly 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 PM25 emissions. These emissions, if not properly 

managed, can reach smoke-sensitive areas m1d have significant negative impacts on the air quality in 

these areas. Smoke-sensitive areas include Georgia's heavily-populated areas and PM2.

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 prescribed burning, Georgia DNR and the Georgia 

Forest1y Commission formulated and adopted Georgia's Basic Smoke Management Plan (SMP) 

dated April 16, 2008. The plan was developed in accordance with EPA's "The h1terim Air Quality 

Policy on Wildland and Prescribed Fires" and the draft 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 protecting public health and welfare by mitigating 

the impacts of air pollutants from wildland and prescribed fires on air quality and visibility. The plan 

is a necessary component in determining Exceptional Events related to prescribed buming and is an 

element of Georgia's Regional Haze SIP. The Georgia Foreshy Commission (GFC), Georgia 

DNR's EPD, and Georgia DNR's Wildlife Resources Division (WRD) signed a Memorandum Of 

20 of 54 
Atlanta PM2.

5 NonattainmentArea 

Redesignation Request and Maintenance Plan 

Understanding (MOU) to implement the SMP on April 16, 2008. The SMP and the MOU are 

included as Appendix B. 

The SMP identifies the following components that should 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 quality 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-certified prescribed fire managers and are supported 

by the GFC's full-time fire weather meteorologist. Air quality monitoring and forecasting, 

perfonned by Georgia EPD, provides impmtant air quality data to assist fire managers with their 

decisions on when to schedule prescribed burns. 

In addition to mitigating the impacts of prescribed burns on air quality, the implementation of a SMP 

has benefits with regard to the computation of air quality design values. Design values are statistical 

measures of historical ambient pollutant concentrations that are compared to EPA's air quality 

standards to detennine if attainment of the standard has been achieved. An atypical event, such as an 

unusually large forest fire, can produce PM2.

5 emissions that will significantly increase ambient 

concentration measurements, and therefore design value computations, in a nonattainment area. EPA 

will allow the atypical ambient measurements to be excluded from the design value computation if 

the fire event is deemed to be an "exceptional 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 state must ensure that the burner employs basic smoke 

management practices. 

All outdoor buming is subject to enforcement through law enforcement officers of GFC, DNR and 

local law enforcement. The enforcement authority is 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 certified prescribed bumers if investigation reveals that 

disregard for basic smoke management practices contributed to smoke intrusion into a smokesensitive area. This measure is State enforceable. It is not necessary for the continued maintenance 

of attainment in the Atlanta area. However, implementation of the SMP will suppmt the maintenance 

of the annual PM 25 NAAQS. 

21 of 54 
Atlanta PM2.5 NonattainmentArea 

Redesignation Request and Maintenance Plan 

2.3.3 Federal Control Measures 

Federal control measures related to ambient PM25 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 Standards and Ultra-Low Sulfur 

Diesel (ULSD) Rule; 

• Large Nonroad Diesel Engines Rule and ULSD Rule; 

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

• NOx SIP Call in Surrounding States. 

All of the measures .were in place prior to 2007, with the exception of the large nonroad diesel rule 

(effective in 2008) and CAIR. Reductions associated 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 controJled 

by each. The continuous drop in PM2.5 concentration from 2005 through 20 I 0 demonstrates that the 

improvement of air quality is due to the implementation of the control measures. Detailed 

discussions of the measures are presented in the following subsections. 

22 of 54 
PM,.s ann. 

avg. {flg/m3), 

Atlanta Area 

Monitors. 

Forest ParkGeorgia DOT 

(13-063-0091) 

KennesawNational 

Guard (13-

067-0003) 

. 

Powder 

SpringsMac1and 

Aquatic 

Center (13-

067-0004) 

South DeKa1b 

(13-089-0002) 

Doraville (13-

089-2001) 

E. Rivers 

.School (13-

121-0032) 

Fire Station 

No.8 (13-121-

0039) 

Georgia Tech 

(13-121-0048) 

Gwinnett Tech 

(13-135-0002) 

GainesvilleFair Street 

School (13-

139-0003) 

Yorkville (13-

223-0003) 

Atlanta PM2.s Nonattainment Area 

Redesignation Request and Maintenance Plan 

Table 2-6. Timetable of Federal Measure Implementation 

2003 2004 2005 2006 2007 2008 

16.0 16.8 16.6 16.7 15.3 13.7 

16.0 15.8 16.3 16.5 15.3 13.5 

15.2 15.2 15.5 15.8 14.5 13.1 

15.0 16.1 15.5 15.4 14.8 12.7 

15.4 15.5 15.8 14.5 15.1 13.1 

16.1 16.1 15.9 15.4 15.7 13.0 

17.7 17.6 17.0 18.4 -- 7.6 

-- -- -- 15.1 15.5 14.3 

16.2 16.1 16.1 16.9 14.2 12.4 

14.7 14.0 14.5 13.8 13.4 l1.8 

13.8 13.4 14.6 13.9 14.3 11.9 

23 of 54 

2009 2010 

. 

11.5 13.4 

11.2 12.2 

10.3 12.1 

11.4 12.3 

11.7 12.2 

11.6 12.2 

]2.1 14.5 

-- --

11.6 12.3 

10.2 l1.4 

9.9 11.2 
Clean Air 

Interstate Rule 

(CAIR) 

Tier 2 vehicle 

standards 

Heavy Duty 

Engine 

Standard, first 

phase 

NOx* 

NO, 

NO, 

voc 

Atlanta PM2.s NonattainmentArea 

Redesignation Request and Maintenance Plan 

* also requires S02 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 Transpmt of Fine 

Particulate Matter and Ozone (Clean Air Interstate Rule)'' referred to as CAIR. This rule established 

the requirement for States to adopt mles limiting the emissions of NO, and sulfur dioxide (S02) and 

a modelmle for the states to use in developing their mles. The purpose of the CAIR was to reduce 

interstate transport of precursors to fine patticulate and ozone. 

The CAIR mle applied to fossil-fuel-fired electric generation units (EGUs), including certain 

cogeneration units, with nameplate capacities of greater thatl 25 MWe. This rule set annual state 

caps for NO, and S02 in two phases, with the Phase I caps stmting in 2009 and 2010, respectively. 

Phase II caps for NOx a11d S02 were to become effective in 2015. 

24 of 54 
Atlanta PMz.s NonattainmentArea 

Redesignation Request and Maintenance Plan 

As part of the CAIR rule, EPA determined that Georgia contributed significantly to downwind PM25 

nonattainment areas and/or interfered with maintenance of the PM25 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. 

On July 11, 2008, the U.S. District Court of Appeals in the District of Columbia vacated the Clean 

Air Interstate Rule and remanded it to EPA. A rehearing of the Court's decision was requested and 

granted. On December 23, 2008, the comi remanded CAIR to EPA without vacatur (i.e., the rule 

was still in place). EPA was directed to correct the deficiencies in CAIR that were identified in the 

comi's decision. 

To replace CAIR, EPA promulgated the final Cross-State Air Pollution Rule (76 FR 48208) on 

August 8, 2011. The Cross-state rule imposes restrictions on emissions of NOx and S02 from states 

identified as having significant impacts on ozone and/or PM2_5 NAAQS attainment or as interfering 

with maintenance of these same standards in downwind states. The requirements of the Cross-state 

Rule were to become effective in 2012 and 2014, which is beyond the 2008-to-2010 clean data 

period for the metro Atlanta area. However; on December 30, 2011, the U.S. Comi of Appeals for 

the D.C Circuit Comi issued a ruling to stay CSAPR pending judicial review. Regardless of the 

timing of the transition fi·om CAIR to CSAPR, or the resulting comi-ordered interstate transpmi 

remedy, emissions of NOx and S02 have declined significantly and are expected to continue to 

decrease in the future due to the continuation of CAIR and Georgia's own EGU emission rules. 

2.3.3.2 Tier 2 Vehicle Standards and Low-Sulji1r Gasoline 

Federal Tier 2 vehicle standards will reduce NOx emissions from passenger vehicles. The standards 

require all passenger vehicles in a manufacturer's fleet, including light-duty trucks and sp01i utility 

vehicles (SUVs), to meet an average standard of0.07 grams ofNOx 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 rating (the larger pickup trucks and SUVs), which 

are not covered by the current Tier I regulations. For these vehicles, the standards were phased in 

begirming in 2008 with full compliance in 2009. The new standards require vehicles to be 77% to 

95% cleaner than those on the road prior to implementation of Tier 2. The Tier 2 rule also reduced 

the sulfur content of gasoline to 30 parts per million (ppm) stariing in January of2006. Sulfur occurs 

naturally in gasoline but interferes with the operation of catalytic converiers on vehicles resulting in 

higher emissions. Lower-sulfur gasoline is necessary to achieve the Tier 2 vehicle emission 

standards. 

2.3.3.3 Heavy-Duty Gasoline and Diesel Highway Vehicles Standards & Ultra Low-Sulfiw Diesel 

Rule 

New U.S. EPA standards designed to reduce NOx and VOC emissions from heavy-duty gasoline and 

diesel highway vehicles (14001 pounds or more) began to take effect in 2004. A second phase of 

standards and testing procedures, which began in 2007, will reduce particulate matter from heavyduty highway engines and will also reduce highway diesel 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 

pariiculate matter (PM) emissions and a 95% reduction in NOx emissions for these new engines 

using low sulfur diesel, compared to older engines using diesel with higher sulfur content. S02 

emissions will also be reduced due to the lower fuel sulfur content. 

25 of 54 
Atlanta PM2.s NonattainmentArea 

Redesignation Request and Maintenance Plan 

2.3.3.4 Large Nonroad Diesel Engines Rule & Ultra Low-Suifitr 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 mles also reduce the allowable sulfur in nonroad diesel fuel by over 99%. Prior 

to 2006, nonroad diesel fuel averaged about 3,400 ppm 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 

NOx and PM emissions from large nonroad diesel engines by over 90%, compared to older engines 

using diesel with higher sulfur content. S02 emissions will also be reduced due to the lower fuel 

sulfur content. 

2.3.3.5 Nonroad Large Spark-Ignition Engines and Recreational Engines Standard 

This standard, effective in July 2003, regulates NOx, hydrocarbons (HC) and carbon monoxide (CO) 

for groups of previously unregulated nonroad engines. The new standard applies to all new engines 

sold in the United States and impmted after these standards began and apply to large spark-ignition 

engines (forklifts and airpmt ground service equipment), recreational vehicles (off-highway 

motorcycles and all-terrain-vehicles), and recreational marine diesel engines. The regulation varies 

based upon the type of engine or vehicle. 

The large spark-ignition engines contribute to ozone fonnation and ambient CO and PM levels in 

urban areas. Tier I of this standard was ·implemented in 2004 and Tier 2 started in 2007. Like the 

large spark-ignition engines, recreational vehicles contribute to ozone fonnation 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 kilowatts are used in yachts, cruisers, and other types of 

pleasure craft. Recreational marine engines contribute to ozone fmmation and PM levels, especially 

in marinas. Depending on the size of the engine, the 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% reduction in NO"' and 56% reduction in CO 

emissions are expected by 2020. These controls will help reduce ambient concentrations of ozone, 

CO, and fine PM. 

2.3.3.6 NO,, SIP Call in Suwounding States 

In October 1998, the U.S. EPA made a finding of significant contribution of NOx emissions from 

certain states and published a rule that set ozone season NOx budgets for the purpose of reducing 

regional transport of ozone ( 63 FR 573 56). This rule, referred to as the NO, SIP Call, called for 

ozone season controls to be put on utility and industrial boilers, as well as internal combustion 

engines in 22 states in the Eastern United States. A NOx emissions budget was set for each state and 

the states were required to develop rules that would allow the state to meet their budget. A NOx 

trading program was established, allowing sources to buy credits to meet their NOx budget as 

opposed to actually installing controls. The emission budgets were to be met by the beginning of 

2004. 

26 of 54 
Atlanta PM2.s Nonattainment Area 

Redesignation Request and Maintenance Plan 

2.3.4 S01 Emissions Reductions in Upwind States 

As noted previously, secondary sulfate concentrations in a given location can be significantly 

affected by S02 emissions from distant sources. During the period of2003 through 2009, S01 

emissions fium coal-fired electric generation facilities upwind of Georgia have been significantly 

reduced. 

EPA promulgated the Cross-State Air Pollution Rule (76 FR 48208) on August 8, 2011, and projected 

future emissions to support the rulemaking. Modeling in support of the Cross-State Rule has 

established linkages between emissions fi·om upwind states and ambient PM25 concentrations in 

downwind receptor states. EPA's projections indicate that 2012 emissions for the base case (which 

disallows reductions from existing or future CAIR controls) from ten upwind states will contribute 

0.15 f!g/m3 (1% of the 1997 annual PM 2_5 standard) or more to ambient PM2_5 concentrations in 

Georgia's 2012 projected nonattainment area (Atlanta). 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 Final Rule Teclmical Support Document, June 

2011, docket item EPA-HQ-OAR-2009-0491-4140.] 

Table 2-7 shows the S02 emissions trends 11-om coal-fired EGU facilities in the ten upwind states 

during the period 2003 through 2009. The total S02 emissions from the ten states dropped 

approximately 15 percent fi·om 2003 to 2007 and over 50 percent from 2003 to 2009. The trend of 

aggregated S02 emissions from these states is presented in Figure 2-6. 

27 of 54 
Atlanta PM2.5 NonattainmentArea 

Redesignation Request and Maintenance Plan 

Table 2-7. Annual 802 Emissions in States With Downwind Contributions to Georgia 

PMz.s Exceeding 0.15 )lg/m3 

.··· 

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 the upwind states are not permanent and 

enforceable reductions in Georgia. However, we believe that the reductions provide further evidence 

that the reduced PM25 levels in Georgia dul'ing the period 2008-20 I 0 are due to S02 emissions 

reductions achieved both within and outside Georgia. The majority of upwind reductions is due to 

state rules or consent orders requil'ing reduced S02 emissions. With the promulgation ofthe CrossState Air Pollution Rule, it is highly unlikely that 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 review. Regardless of the timing of the transition 

from CAIR to CSAPR, or the resulting court-ordered interstate transpmt remedy, emissions of S02 

from upwind states have declined significantly and are expected to continue to decrease in the 

future.) 

28 of 54 
"' 

Atlanta PM2.s Non attainment Area 

Redesignation Request and Maintenance Plan 

7,000,000 

6,000,000 

5,000,000 

§ 4,000,000 

lliil! Upwind States I ""' "' 3,000,000 0 

"' 2,000,000 

1,000,000 

0 

2003 2005 2007 2009 

Figure 2-5. Trend of Aggregated Annual S02 Emissions in States with Downwind 

Contributions to Georgia PM2.5 Exceeding 0.15 )tg/m3 

2.4 Section 110 and PartD Requiremenls 

Section 11 0 of the CAA contains the requirements for state implementation plans (SIPs). The 

purpose of a SIP is to provide for the implementation, maintenance, and enforcement of national 

primary ambient air quality standards. Part D, Subpmt I, of CAA Title I (Sections 171 to 1 79) 

contains general requirements for areas that have been designated nonattainment. As stated in 

Section 1.1 of this maintenance plan, the Atlanta area was designated as nonattainment for the 1997 

annual fine PM standard in April of2005. 

Georgia EPD submitted a PM2.5 nonattainment plan for the Atlanta area per Title I Pmt D. With the 

determination that the Atlanta nonattainment area has attained the 1997 annual fine PM standard 

(Section 2.1.3), the area is no longer subject to the nonattainment provision ofCAA Section 110 and 

Part D requirements for demonstrating attainment, RFP, associated RACM and contingency for areas 

designated as nonattainment with the NAAQS. Therefore, the nonattainment plan was subsequently 

withdrawn. All other Section 110 and Part D requirements pe1taining to the Atlanta area have 

previously been approved or are cmTently subject to approval by EPA. 

29 of 54 
Atlanta PM2.s NonattainmentArea 

Redesignation Request and Maintenance Plan 

3.0 Maintenance Plan 

Section 175A of the Clean Air Act Amendments of 1990 defines the general framework of a 

maintenance plan. The core provisions of Section 175A are a quantitative demonstration of 

maintenance of the standard (PM2.5 in this case) and contingency provisions for prompt adoption of 

corrective measures if attainment is not maintained. Per guidance from EPA,4 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 use the ambient monitoring network for verification 

of continued attainment m; if applicable, for triggering contingency provisions. 

3.1 Maintenance Demonstration 

Section I 75A of the CAA requires a state that is requesting redesignation to submit a revision to its 

SIP which provides for maintenance of the applicable standard for a minimum of I 0 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. Therefore, Georgia EPD is providing a demonstration 

of maintenance through the year 2024. 

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 

intennediate years. If each of the projected emission levels is less than the emission level for the 

attainment yem; maintenance of the standard is demonstrated. This assumes that ambient 

concentrations will remain below the standard if future annual emissions are kept below the 

inventoried emissions in the chosen attainment yem·. Under the second maintenance demonstration 

method, air quality modeling is used to project ambient pollutant concentrations and annual design 

values for the final year and inte1mediate years. If all ofthe modeled, rolling 3-year averages of the 

annual design values are below the standard, maintenance is demonstrated. 

Georgia EPD has adopted the method of comparing attainment year emissions to projected emissions 

for this maintenance plan. This approach has been used in the previous maintenm1ce plans submitted 

by EPD and approved by EPA. The following sections discuss the attainment year inventory, the 

projected inventories, and verification of continued attainment. 

3.1.1 Attainment Year Emissions Inventory 

Georgia EPD has selected 2008 as the year for the attainment year emissions inventory. 2008 is one 

of the tlu·ee years (2008-2010) on which the Atlanta area's clean data detennination is based. Most 

of the 2008 base-year emission inventmy was obtained from the National Emissions Inventory 2008 

Version 1.5 (NEI2008, http://www.epa.gov/ttnchiel/net/2008inventory.html). The following 

emissions sectors are included in the inventory; 

4 "Procedures for Processing Requests to Redesignate Areas to Attainment", September 4, 1992, John 

Calcagni, Director, Air Quality Management Division, OAQPS, USEPA 

30 of 54 
Atlanta PM2.s NonattainmentArea 

Redesignation Request and Maintenance Plan 

• Point sources (EGU and non-EGU), 

• Nonpoint somces (including fire), 

• Onroad mobile sources, and 

• Nonroad mobile somces (including marine vessels, aircraft, and rail). 

The data sources for the attainment-year emissions inventories are summarized in Table 3-1. 

Additional details on the data somces and inventory methods are presented in the following 

subsections and in Appendix C. 

Table 3-1. 2008 Emissions Inventory Sources 

..•.. ·· . < . .· · .. ··.····· .. · .... · ... · ... ··· ... ···.·· Em,s$i()IIS.§ource 1 

. Inventory §Qllrc~ ·.· .....•.... 

•. ···•···· · S~ctor ·········•·· .. •··. . .. ··.·•·.···· · .... '• .. ·.. . . 

Point-EGU NEI2008 Version 1.5 

Point- non-EGU NEI2008 Version 1.5 

Non point NEI2008 Version 1.5 

Omoad Mobile ARC MOVES2010 

Nomoad Mobile NEI2008 Version 1.5 

3.1.1.1 PointSources 

Point sources captmed in the inventory include stationary sources whose actual emissions equal or 

exceed I 00 tons per year of S02, NOx. or patiiculate matter. Emissions from point somces have been 

calculated for EGU and non-EGU sources. 

EGU Point Sources: 

The nonattainment m·ea has six EGU facilities located within its boundaries that repmi their 

emissions for the emissions inventmy. Three facilities, Doyle Generating (AIRS No. 29700041), 

MPC Generating (AIRS No. 29700040), and Walton County Power (AIRS No. 29700042) operate 

natural gas-fired combustion turbines and fall below the reporting threshold for the emission 

inventory, thus they have never repmied emissions to the Division. Table 3-2 summarizes emissions 

from each EGU located in the nonattainment area that is required to repmi its emissions for the 

emission inventmy. 

31 of 54 
Facility Site Name 

Atlanta PM2.s NonattainmentArea 

Redesignation Request and Maintenance Plan 

Table 3-2. Emissions by EGU facilities in 2008, 2017 and 2024 

AIRSID 2008 2017 

SOz NOx PMzs SOz NOx PMzs 

2024 

S02 NOx 

Chattahoochee Energy Facility 14900006 5 97 89 4 86 79 5 103 

GA Power Company -Plant Bowen 01500011 149,015 25,360 2,003 8,781 7,763 1,219 9,123 8,066 

GA Power Company -Plant Branch 23700008 93,982 20,194 445 4,972 3,740 236 5,166 3,885 

GA Power Company -Plant 

McDonough/ Atkinson 06700003 24,330 3,489 202 25 451 283 29 536 

GA Power Company -Plant 

Wansley 14900001 74,956 14,625 1,866 4,086 4,116 1,069 4,246 4,299 

GA Power Company - Plant Yates 07700001 68,208 12,413 333 30,648 6,557 285 31,844 6,813 

Total 410,496 76,177 4,937 48,517 22,713 3,171 50,414 23,702 

Non-EGU Point Sources: 

2008 emissions of SOz, NO" and PM25 from EGU and non-EGU facilities are presented in Table 3-

3. Chemical Products Corporation in Bmtow Cmmty is the largest source of S02 emissions from 

non-EGU point sources in the Atlanta Area, while Owens Corning Insulating Systems LLC, is the 

largest source of PM,5 emissions from non-EGU point somces. 

Table 3-3. Point Source Emissions for 2008 (tons, annual) 

Pollutant EGU Non-EGU Total Point 

' · .. 

so, 410,496 2,982 413,478 

NOx 76,177 4,608 80,785 

PM,.s 4937 700 5637 

The 2008 point source inventory is based on the National Emissions Inventmy (NEI) repmts for 

reporting year 2008. Emissions from sources that repmted for 2008 were generally used as reported. 

See Appendices C and C-1 for more details on the development of the 2008 point source emissions 

inventmy. 

3.1.1.2 Nonpoint Sources 

Nonpoint sources captured in the inventmy include stationmy sources whose emissions levels of 

S02, NO" and particulate matter are each less than 100 tons per year. Emissions estimates for nonEGU point sonrces in 2008 were obtained from NEI2008 Version 1.5. 

The 2008 nonpoint source emissions for the Atlanta area are presented in Table 3-4. The largest 

contributors to S02 emissions were coal-fired and residual-oil-fired industrial boilers. The largest 

contributors to NOx emissions were industrial wood-fired boilers and Class I diesel railroad line haul 

locomotives. The largest contributors to PM25 emissions were industrial wood-fired boilers and road 

dust from unpaved roads. 

32 of 54 

PM, 

94 

1,267 

245 

336 

1,119 

297 

3,358 
Atlanta PM2.5 NonattainmentArea 

Redesignation Request and Maintenance Plan 

Emissions from fires in 2008 were also obtained from NEI2008 Version 1.5 and are shown in Table 

3-4. These estimates were provided by Georgia Environmental Protection Division as part of the 

AERR2008 submission (Georgia Air Protection Branch, 20 II). This inventmy was developed using 

2008 burned-area data and buming permit data provided by Georgia Forestty Commission, and the 

same method as used for the VISTAS2002 fire inventmy. 

Table 3-4. Nonpoint Source Emissions for 2008 (tons, annual) 

Pollutant Nonpoint Fire Total 

(excluding .fire) Nonpoint 

so, 10,203 34 10,237 

NOx 20,992 201 21,193 

PM2.5 34,921 765 35,686 

The 2008 level of PM25 emissions fi·om nonpoint sources, excluding fire, was 34,921 tons. This 

quantity accounted for over 50 percent of total PM2.

5 emissions in the Atlanta area. The top three 

nonpoint source classifications for PM2.5 emissions were industrial wood-fired boilers, dust from 

unpaved roads, and dust from paved roads (see Table 3-5). 

Table 3-5. Largest Nonpoint PM25 Emissions by Source Classification 

sec Description 2008PM,.s 

(tons) 

2102008000 Stationmy Fuel Comb /Industrial /Wood /Total: 12,192.03 

All Boiler Types 

2296000000 Unpaved Roads /All Unpaved Roads /Total: 10,421.06 

Fugitives 

2294000000 Paved Roads I All Paved Roads /Total: Fugitives 2627.17 

3.1.1.3 Onroad Mobile Sources 

U.S. EPA's MOVES20 I Oa mobile source emissions model was run in inventory mode to generate 

2008 on-road mobile source emissions of S02, NO" and PM25• The 2008 omoad mobile source 

emissions for the Atlanta area are presented in Table 3-6. 

Table 3-6. Onroad Mobile Source Emissions for 2008 (tons, annual) 

Pollutant Onroad 

Emissions 

so, 725.14 

NOx 128,954.56 

PM25 4,661.88 

33 of 54 
Atlanta PM2.s NonattainmentArea 

Redesignation Request and Mftintenance Plan 

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. 

SO, NOx and PM2.s emissions from onroad mobile sources in 2008 and 2024 were developed by the 

Atlanta Regional Commission using MOVES20 I Oa. MOVES was nm separately for two groups of 

twenty nonattainment counties in Atlanta in inventory mode. The two groups of counties have 

different JIM program requirements, and they are the Atlanta 13-county area and the Atlanta 7-

county area. 

Average 2008 annual daily meteorological inputs were used. Best available local data were used for 

MOVES inputs such as vehicle population, vehicle miles traveled (VMT) by source types, road type 

distribution, speed distributions, ramp fractions, hourly VMT fractions and age distribution. 

Since there is no public road in the nonattainment part of Heard County, MOVES was not nm for 

Heard County. MOVES was run for whole county of Putnam, and the emissions in the partial 

nonattainment area were calculated using human population fraction. Local vehicle population and 

VMT were used for the Putnam County inputs. Please refer to the document "MOVES-Based 

Mobile Source Emissions Modeling for the Atlanta Nonattainment Area" provided by the Atlanta 

Regional Commission in Appendix C-7 for more detailed information. 

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 engines not modeled in NONROAD, specifically 

aircraft, commercial marine vessels, and locomotives. 

Emissions from aircrafts and locomotives in 2008 were obtained from NEI2008 Version 1.5 

(http://www.epa.gov/ttnchiel/net/2008inventoty.html). Emissions fi·om yard locomotives were not 

included in the NEI2008, and were obtained from Eastern Regional Technical Advisoty Committee 

(ERTAC) separately. There were no emissions from commercial marine vessels in the Atlanta PM2.s 

nonattainment area. 

Table 3-7. Nonroad Mobile Source Emissions for 2008 (tons, annual) 

Pollutant Nouroad- Aircraft Locomotive Total 

except air and Non road 

rail 

so, 474 1,142 59 1675 

NOx 24,616 10,189 5794 40,599 

PM25 2351 293 183 2827 

34 of 54 
Atlanta PM2.s NonattainmentArea 

Redesignation Request and Maintenance Plan 

3.1.1.5 Summary of2008 Emissions InventOJy 

The total 2008 Atlanta nonattainment area emissions of S02, NO"' and PM2.5 are presented for each 

source sector in Table 3-8. The majority of S02 emissions, by fat; are from point sources. The 

majority of NOx emissions are from point and onroad mobile sources. The majority of PM25 

emissions are from nonpoint and point sources. 

Table 3-8. Attainment-year (2008) Emissions Inventory (tons, annual) 

Pollutant .. Plllnt •. · .. Point··.· Point. ··•·.· N9np()irit (>j\roa£1 Noriroad I'·····Totaii. 

•••• TIJtal• .EGU I•' Non~· 

······.··.·.····· i i.< 

Mobile 1 Mobile, 

---\ ... · •. ·.·•·.·. .· ' \< . . < 

< · .. · < .. · EGU .. ·.·.···•·. ·.· .....•... · .... 

so, 413,478 410,496 2,982 10,237 725 1,675 426,115 

NOx 80,785 76,177 4,608 21,193 128,955 40,599 271,531 

PM25 5,637 4,937 700 35,686 4,662 2,827 48,811 

3.1.2 Projected Emissions Inventories 

As discussed previously, Georgia EPD is providing a demonstration of maintenance through the year 

2024 (the maintenance year). Emissions projections to suppmt maintenance through 2024 have been 

prepared for the years 2017 and 2024. In addition, emissions have been calculated by interpolation 

for the years 2014 and 2020. Emissions for these additional years provide additional reference 

points for periodic assessment of maintenance of the standard. Maintenance period emissions 

controls, projection methods, and projected inventories are discussed in the remainder of this 

subsection. 

3.1. 2.1 Methods and Projected Inventories 

Projected emissions inventories are calculated by applying applicable control and growth factors to 

the 2008 emissions of individual sources or source categories. The control and growth factors may 

apply for some or all of the years 2008 (year following attainment inventmy) through 2024 (out 

year). The bases used to determine these factors are summarized in Table 3-9. 

35 of 54 
Atlanta PM2.5 NonattainmentArea 

Redesignation Request and Maintenance Plan 

Table 3-9. Bases of Control and Growth Factors for 2017 and 2024 Inventories 

.~:::.;z ',•b , r , , · iJ~~i1l8rN' , ~· . ·': ' ? · ..··•· ~ · ' .···.··. "'·.~ •. ~ { ;~'1 f'{}('~Wf [~;;,·;,·p!'[)\",{;'\•''! t?ccc%~~t;ft"a~ 'jj.liSiS. •·· ::'"' ,, j";;. .,.:l'· r,•.i'') ··•···· o''3/ii !~i,l;'i'1''· ;. !.·• 

Point-EGU Implementation of GA Rule (sss) Coal consumption forecasts in 2010 

for S02 and NO, controls; VISTAS Annual Energy Outlook (AEO) 

2012 projection inventmy 

Point- non-EGU Regulatmy review - no additional EGAS growth factors by SCC and county 

controls defined at this time for 2017 and 2024. 

Nonpoint Regulatory review - no additional EGAS growth factors by SCC for 2017 

controls defined at this time and 2024. 

Nonpoint- fire No additional controls anticipated No growth anticipated 

Onroad Mobile MOVES inventory mode (PM25, MOVES inventmy mode (PM25, NO, 

NO, S02) for 2024. All known SOz) for 2024. Vehicle population growth 

Federal controls. from human population projections. 

Vehicle miles traveled (VMT) growth 

from Georgia DOT. 

Nonroad Mobile NM1M2008 NM1M2008 

Nonroad Mobile SEMAP (Feehan) control factors SEMAP (Feehan) growth factors by SCC 

-marine, by sec for 2017 and 2024 for 2017 and 2024 

aircraft, and rail 

The pollutants whose emissions are projected are SOz, NO, and direct PM2.5• As with the attairnnent 

inventory, emissions from the following sectors are projected: 

• Point sources (EGU and non-EGU), 

• Nonpoint sources (including fire), 

• Onroad mobile sources, and 

• Nonroad mobile sources (including marine vessels, aircraft, and rail). 

The projected inventories are presented in the following subsections. The methods used to develop 

the emissions projections are presented in more detail in Appendix C. 

36 of 54 
3.1.2.2 Point Sources 

EGU Point Sources: 

Atlanta PM2,5 Nonattainment Area 

Redesignation Request and Maintenance Plan 

EGU point source emissions in 2017 and 2024 were estimated using growth factors and control 

factors. Growth factors were calculated based on coal consumption for the southeastem region in the 

Energy Information Administration's AE020 I 0 repmi. The control factors varied with pollutants. 

The S02 control factor associated with Flue Gas Desulfurization (FGD) was assumed to be 95% 

according to VISTAS 2012 Projection Emissions Inventmy. The NOx control factor associated with 

Selective Catalytic Reduction (SCR) was assumed to be 82.5% according to VISTAS 2012 

Projection Emissions Inventmy. The PM25 control factor associated with FGD was assumed to be 

50% according to Table 5.4-1 on page 5.4-24 of the EPA document "Stationaty Source Control 

Techniques Document for Fine Particulate Matter" (EC/R Incorporated, 1998). When FGD or SCR 

controls were already operated fully or partially at a unit during year 2008, the control factors were 

only applied to uncontrolled emissions in 2008. These periods were identified using CAMD hourly 

CEM data for NOx and S02 emissions and heat inputs. Days without control operation were 

identified as those days on which the ratio ofNOx or S02 emissions to heat input exceeded 0.00004 

lbs/mmBtu according to correlation analysis results. In addition, NOx emissions during the period 

from October I, 2008, to December 31, 2008, fi·om Plant Bowen Unit 3 were projected to futlll'e 

years using a different method, since the actual NOx control efficiency in this period was 

approximately 60% according to hourly CEM data analysis. Such NOx emissions were first adjusted 

to reflect before control emissions and then apply the 82.5% NOx emissions control factor for futlll'e 

year emissions projection. 

The S02 control factor due to Flue Gas Desulfurization (FGD) was assumed to be 95% according to 

the VISTAS 2012 Projection Emissions Inventory (see Appendices C and C-6). In 2008, Plant 

McDonough operated two coal-fired EGUs (Units 1 and 2) with a combined generating capacity of 

530 MW. Due to the requirements specified in Georgia's Rule 391-3-1-.02(2)(sss) for EGU controls, 

Georgia Power shut down Unit 2 by the fourth quarter of2011 and Unit 1 by the second quarter of 

2012. Unit 2 was replaced with two gas-fired combined cycle blocks (Blocks 4 and 5), and Unit 1 

was be replaced by one gas-fired, combined cycle block (Block 6). Each block consists of two 

generating units, with each unit consisting of a combustion turbine and a duct burner. The combined 

generation capacity of the three blocks (six units) is 840 MW. Two of the six combustion turbines 

are permitted to burn distillate oil (0.0015 %sulfur) up to 1000 hours/year each. NOx emissions 

from each unit are controlled by an SCR and a !ow-N Ox burner. 

As noted in Subsection 2.3.3, EPA promulgated CSAPR in 20ll, but the rule was stayed later in the 

year. When the rule was promulgated, Georgia was identified as a covered state and, therefore, 

would have been required to comply with statewide allocations of S02 and/or NOx emissions fi·om 

covered EGUs starting in 2012. The future of the rule is not known at this time; 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. 

Forecasts ofNOx emissions fi·om McDonough's Blocks 4, 5, and 6 were calculated by assuming that 

actual rolling 12-month emissions will be 75% of the permitted limits. It was assumed that the 

duration of operation for these gas-fired units will not push NOx emissions beyond 75% of their 12-

month permit caps. It was also assumed that the two affected combustion turbines would burn oil for 

500 hours per year each. Growth factors were calculated for McDonough-Atkinson using the same 

fuel consumption approach that is described above, subject to the constraint that annual emissions 

cannot rise above the permitted 12-month limits. 

37 of 54 
Atlanta PM2.5 NonattainmentArea 

Redesignation Request and Maintenance Plan 

Projected EGU point source emissions are presented in Table 3-10. The projections show a dramatic 

reduction in S02 emissions as well as significant reductions in NOx and PM2.

5 emissions. Emissions 

levels for 2014 were calculated by linear interpolation between 2008 and 2017. Emissions levels for 

2020 were calculated by linear interpolation between 2017 and 2024. 

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

Pollutant 2008 2014 2017 2020 2024 

(attainment) . 

EGU 

so, 410,496 169,056 48,517 49,331 50,414 

NOx 76,177 40,517 22,713 23,138 23,702 

PM2.s 4,937 3,759 3,171 3,251 3,358 

Non-EGU 

so, 2,982 3,115 3,181 3,270 3,389 

NOx 4,608 4,972 5,154 5,397 5,721 

PM2.s 700 781 822 868 930 

Total Point 

so, 413,478 172,170 51,697 52,601 53,803 

NOx 80,785 45,489 27,867 28,535 29,423 

PM25 5,637 4,541 3,993 4,120 4,288 

Non-EGU Point Sources: 

Projected non-EGU point source emissions for each facility in 2017 aud 2024 can be found in 

Appendix C-3. The emissions for 2017 and 2024 were estimated using SCC-specific and countyspecific growth factors generated with EPA's Economic Growth Analysis System Version 5.0 (EGAS 

5.0). Appendix C-2 contains the SCC-specific growth factors for the Atlanta area. The projections 

show moderate increases in emissions of all three pollutants. No additional future controls can be 

defined for non-EGU point sources at this time. Emissions levels for 2014 aud 2020 were calculated 

by interpolation as described above and can be found in Appendix C. 

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 S02 as well as moderate decreases in emissions 

ofNOx and PM2.s· 

3.1.2.3 Nonpoint Sources 

Nonpoint source emissions, excluding fire, in future years 2017 and 2024 were estimated using SCCand county-specific growth factors generated with EGAS 5.0. Appendix C-2 contains the SCC38 of 54 
Atlanta PM2.s NonattainmentArea 

Redesignation Request and Maintemmce Plan 

specific growth factors for the Atlanta area. No additional future controls can be defined for these 

sources at this time. 

Projections of nonpoint source emissions are presented in Table 3-11. Emissions from fire in future 

years 2017 and 2024 were assumed to be the same as 2008 emissions. The projections show a small 

increase in emissions of S02 as well as moderate increases in emissions ofNOx and PM25• 

Table 3-11. Projected Nonpoint Source Emissions (tons) 

Pollutant 2008 2014 2017 2020 2024 .. (attainment) 

Nonpoint 

(excludinf! fire) 

so, 10,203 10,523 10,683 10,850 ll,073 

NOx 20,992 23,330 24,498 25,716 27,337 

PM25 34,921 39,287 41,467 43,307 45,755 

Fire 

so, 34 34 34 34 34 

NOx 201 201 201 201 201 

PM2_5 768 765 765 765 765 

Total Nonpoint 

so, 10,237 10,557 10,717 10,884 ll,107 

NOx 21,193 23,531 24,698 25,916 27,537 

PM25 35,686 40,052 42,232 44,072 46,520 

The top three nonpoint source classifications for 2024 PM2_5 emissions are industrial wood-fired 

boilers, dust from unpaved roads, and dust from paved roads (see Table 3-12). Projected PM2.5 

emissions from these th1·ee somce classifications make up over 70 percent of total projected PM25 

emissions. 

Table 3-12. Largest N onpoint PM2_

5 Emissions by Source Classification, Year 2024 

sec Description 2024PM2.s 

_· (tons) . ·"• 

2102008000 Stationmy Fuel Comb /Industrial /Wood /Total: 15,972 

All Boiler Types 

2296000000 Unpaved Roads /All Unpaved Roads /Total: 13,652 

Fugitives 

2294000000 Paved Roads I All Paved Roads /Total: Fugitives 3442 

39 of 54 
Atlanta PM2.s NonattainmentArea 

Redesignation Request and Maintenance Plan 

3.1.2.4 Onroad Mobile Sources 

EPD ran U.S. EPA's MOVES2010a mobile source emissions model in inventory mode to generate 

2024 onroad mobile source emissions of SO, NO, and PM25• Intermediate year emissions were 

generated by interpolating between 2008 and 2024. 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 2010 defaults 

were used for Heavy-Duty Diesel Vehicle Class 8B. Person population growth projections for the 

Atlanta metropolitan area were used to calculate the 2024 vehicle population. The 2024 annual 

VMT were calculated by Georgia DOT using travel demand model outputs and HPMS counts, as 

well as speed distribution, road-type distribution, and ramp fraction. Temperature and humidity 

inputs were assumed to be the same as year 2008. 

The projected onroad mobile source emissions levels are presented in Table 3-13. Onroad emissions 

of all t!u·ee pollutants trend downward significantly during the maintenance period. The trend in S02 

is of less importance since onroad mobile sources emit vety little S02• For a detailed discussion on 

how the onroad mobile emission inventory was developed, see Appendices C, C-3, and C-4. 

Table 3-13. Pmjected Onroad Mobile Source Emissions (tons) 

Pollutant 2008 2014 2017 2020 2024. 

(tons)· (attainment) .. 

sol 725 629 581 533 469 

NOx 128,955 93,806 76,258 58,675 35,272 

PM25 4662 3529 2963 2397 1642 

3.1.2.5 Nonroad Mobile Sources 

Projections of nonroad emissions in 2017 and 2024, excluding air and rail sources, were calculated 

using NMIM2008 with the same meteorological inputs as for 2008. Defaults in NMIM 2008 were 

used for other inputs. 

40 of 54 
Atlanta PM2.s NonattainmentArea 

Redesignation Request and Maintenance Plan 

Growth factors for all aircraft engine and airport-related SCCs were based on landing and take-off 

operation (LTO) projections available fi·om the Federal Aviation Administration's Terminal Area 

Forecasts (FAA, 2010). Growth rates for military aircraft were held constant at 2008 levels. No 

control factors were applied to aircraft emissions. 

Growth factors for freight rail sector emissions were based on fuel consumption forecasts. For 

passenger and commuter rail, growth factors were developed from national forecasts of intercity rail 

diesel consumption and commuter rail diesel consumption. 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 3-14. Total emissions of 

NOx and PM25 trend downward significantly during the maintenance period while S02 emissions 

slightly increase. For a detailed discussion on how the nonroad mobile emissions projections were 

developed, see Appendix C. 

Table 3-14. Projected Nonroad Mobile Source Emissions (tons) 

Pollutant 2008 2014* 

~---~ ~~~----+--:2~4,-;-;6> J~6r. PM25 2351 -7#//~ 

so, 1142 ~ 

1-~ NC8x~---l-----,1~ o,,~118=-u,9w.%'i 

PM,5 293 

so,_ 

NOx 

Total 

so, 

*' 

59 

5794 

183 

1675 

40 ')QQ 

~. llo 2014 and 2020 , 

aircraft and 

1516 

14 ORii 

21.@_ 

emiss~::;y for total 

41 of 54 

2017 2020* 2024 

~ 3_7_ 

14,240 10,252 

1687 ~ 1288 

1401 ~ .0 1668 

12,557 ~Y/~__.1"-'4,,c:..:....:....j974 

347 404 

1437 1553 

30,835 29,747 

1~7 

3 

3072 

63 

1708 

?R ?QR 

Jill_ 
Atlanta PM2.s NonattainmentArea 

Redesignation Request and Maintenance Plan 

3.1.3 Emissions Projections Summary and Demonstration ofMaintenance of Attainment 

The consolidated emissions projections for all Atlanta nonattainment area sources are presented in 

Table 3-15. Emissions of 802 and NOx drop significantly from 2008 to 2024. This is a reflection of 

the implementation of the majority of state and federal controls during the first half of the 

maintenance period. Overall, emissions of 802 and NOx are projected to decline by 84.3 percent and 

55.6 percent, respectively, over the course of the maintenance period. 

Emissions of PM25 rise slightly from 2008 through 2017 and then once again from 2017 through 

2024. This is a reflection of an increase in nonpoint source emissions that is partially offset by 

reductions fi·om point sources. The overall rise in PM25 is 11.1 percent of attainment year emissions. 

Therefore, further evaluation is needed to judge whether the increase in PM25 emissions, in 

combination with the decreases in 802 and NOx emissions, is likely to provide for maintenance of the 

standard. 

Table 3-15. Projected Emissions- Total of All Sectors (tons) 

Pollutant (tons) 2008 2014 2017 2020 2024 % change, 

(attainment) ·. 2008-2024 

SOz 426,115 184,873 64,433 65,572 67,088 84.3 

NOX 271,531 196,912 159,659 142,873 120,530 55.6 

PM25 48,811 50,482 51,316 52,556 54,205 -11.1 

Each of the three pollutants is characterized by a different relationship between emissions and air 

quality. Therefore, simply summing the emissions of the pollutants does not provide a meaningful 

indicator of the combined air quality impact of these emission changes. A more appropriate indicator 

is the percentage change in emissions for each emitted pollutant, weighted according to the air 

quality impact for each. 

For this pmpose, Georgia EPD examined speciation data available fi·om the EPA Air Explorer Web 

site for 2007-2009 for the DeKalb County monitor (13-089-0002). The 3-year average of this data 

suggests that ambient PM25 in Atlanta consists of approximately 40.7 percent sulfate; 1.2 percent 

nitrate; 50.1 percent organic patticulate (which consists of directly-emitted primary organic matter 

and atmospherically formed secondary organic aerosol); 4.2 percent miscellaneous inorganic 

patticulate (sometimes labeled "crustal particles"); and 3.7 percent other types of particulate matter. 

Therefore, using a conservative assumption that all of the organic particulate is primary organic 

matter, direct PM25 species make up 54.3 percent (sum of 50.1 and 4.2) of the total ambient PM25 . 

Georgia EPD used a conservative approach that assumes that the full ambient concentration of 

organic particulate matter plus miscellaneous inorganic patticulate matter will vary in accordance 

with changes in total nonattainment area emissions of direct PM2.5• This analysis thus assumes that 

the direct PM25 component of ambient PM2.5 will increase by the 11.1 percent projected increase in 

direct PM25 emissions. This approach was used by U.S. EPA in its evaluation and approval of the 

annual PM2.5 redesignation request for the Evansville, Indiana, nonattainment area (see 76 FR 29695 

and 76 FR 59527). 

42 of 54 
Atlanta PM2.s Non attainment Area 

Redesignation Request and Maintenance Plan 

h1 the Atlanta analysis, the baseline concentration is conservatively assumed to be 15.0 flg/m3. Direct 

PM25 is estimated to contribute 54.3 percent, or 8.1 ~Lg/m , of the 15.0 ~Lg/m • Georgia EPD's 

assessment assumes that the projected increase in direct PM2.s emissions will cause a corresponding 

11.1 percent increase in ambient concentrations of PM2.

5, which would suggest an increase in the 

ambient concentration ofthe direct PM2.s component by 0.905 ~Lg/m . 

However, Georgia EPD believes that this potential increase 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 Atlanta, but also in many other pa1ts of the 

Eastern United States. Modeling conducted by EPA for the Cross-State Air Pollution Rule (CSAPR) 

estimated that future Atlanta concentrations with the final CSAPR in place (12.99 f!g/m3

) would be 

2.01 ~Lg/1113 below the standard (2014 Remedy Average case*). fu addition, the emissions reductions 

that have already occmTed have brought the maximum measured Atlanta concentrations to 13.6 

~Lg/m3 (as shown in Table 2-2). Therefore, the 0.905 ~Lg/m3 increase in the components associated 

with direct PM2.

5 would not be expected to yield concentrations above the standard. That is, GA 

EPD believes that maintenance of the annual PM2.

5 standard is demonstrated despite the small 

projected increase in direct PM2_5 emissions. 

*Air Quality Modeling Final Transp01t Rule Technical Suppmt Document, docket item EPA-HQOAR-2009-0491-4140. 

3.1.4 Emissions Decreases 

An emissions surplus represents the degree of improvement (reduction) in 2024 emissions compared 

to the attainment year (2008) emissions. The surpluses are shown in Table 3-16 for each pollutant. 

A positive surplus reflects an emissions decrease fi"Om the attainment year to 2024. The negative 

surplus for PM2_5 reflects a projected increase in emissions. A portion of the NOx surplus will be 

allotted to the Motor Vehicle Emissions Budget as a safety margin (see Section 4). 

Table 3-16. Emissions Decrease 

Pollutant Surplus 

Emissions* 

2008 to 2024 (tons) 

so, 359,028 

NOx ** 151,001 

PM2.s ** -5394 

* Surplus = (2008 emissions level) - (2024 emissions level) 

**These quantities do not reflect allotment to Motor Vehicle Emissions Budget 

43 of 54 
Atlanta PM2.s NonattainmentArea 

Redesignation Request and Maintenance Plan 

3.1.5 Verification of Continued Attainment 

Items 5.c and 5.d of the September 4, 1992 EPA guidance memo outline requirements for verification 

of continued attainment. Verification of continued attainment is accomplished through operation of 

the ambient PM2.5 monitoring network and through periodic updates of the area's emissions 

inventory. 

The location and operation of EPD's FRM monitors in the Atlanta area are described in Section 2.1 

of this plan. During the maintenance period, EPD will continue to operate federal reference monitors 

in the Atlanta area 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 

December 17, 2008. The most recent triennial inventmy for Georgia was compiled for 2008. The 

larger point sources of air pollution will continue to submit data on their emissions on an annual 

basis as required by the AERR. Emissions Ji'om the rest of the point sources, the non point source 

pmtion, and the onroad and nonroad mobile sources continue to be quantified on a 3-year cycle. The 

inventory will be updated and maintained on a 3-year cycle. As required by the AERR, the next 

overall 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 implemented to correct a violation of the standard, 

should this occur, after redesignation of an area as 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 that were contained in the SIP for the area (i.e., the 

nonattainment plan) before the redesignation. In addition, EPA guidance (John Calcagni memo 

dated September 4, 1992) specifies the following petiaining 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 of additional contingency measures; and 

• a schedule and procedure for adoption and implementation of additional measures (with time 

limit). 

3.2.1 Contingency Measure Triggers 

Section 175A(d) of the Clean Air Act Amendments requires that the maintenance plan include 

provisions for contingency measures that would promptly be implemented by the state to correct any 

violation of the annual PM2.5 NAAQS after redesignation of an area as an attainment area. A Jist of 

potential contingency measures that could be considered for future implementation in such an event 

should also be included in the maintenance plan. 

EPD has developed a contingency plan for the Atlanta PM2.

5 maintenance area. Contingency 

measures are intended to provide further emission reductions in the event that violations of the 

NAAQS occur after redesignation to attainment. Consistent with this plan, EPD agrees to adopt and 

44 of 54 
Atlanta PM2.s Nonattainment Area 

Redesignation Request cmd Maintenance Plan 

implement, as expeditiously as practicable, the necessary corrective actions in the event that 

violations of the standard occur within the maintenance area after redesignation to attainment. 

Contingency measures as described below would be adopted and implemented within 24 months of a 

contingency trigger unless EPD has demonstrated that technical or economic feasibility warranted a 

period longer than 24 months. 

EPD will use actual ambient monitoring and emissions inventmy 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 annual PM25 NAAQS will begin the process to 

implement these contingency measures according to the protocols identified below. The contingency 

plan provides for corrective responses should the NAAQS be violated or if emissions in the Atlanta 

maintenance area increase significantly above current levels. 

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

• the previous calendar year's aunual average PM25 concentration exceeds the standard by 1.5 

ug/m3 

or more; 

• the annual average PM25 concentration in each of the previous two consecutive calendar 

years exceeds the standard by 0.5 ug/m3 

or more; 

• the total maintenance area S02 emissions in the most recent NEI exceeds the corresponding 

attainment-year inventmy by more than 10.0 percent; and 

• the total maintenance area PM25 emissions in the most recent NEI exceeds the 

corresponding attainment-year inventory by more than 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 emission reductions are necessary, EPD will adopt and 

implement any required measures in accordance with Section 3 .2.2. 

The PM25 trigger concentrations described above apply to the PM2.5 federal reference monitors in the 

maintenance area. EPD will evaluate a Tier I condition, if it occurs, as expeditiously as practicable 

to determine the cause(s) of the ambient PM25 or emissions 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 violation of the annual PM25 NAAQS at any FRM 

ambient monitoring station in the Atlanta maintenance area is recorded, based on quality-assured 

monitoring data. In this event, EPD will conduct a comprehensive study to determine the cause(s) 

of the ambient PM25 increase and to determine if the increase is likely to continue and will 

implement any required measures as expeditiously as practicable, taking into consideration the ease 

of implementation and the technical and economic feasibility of selected measures. 

3.2.2 Schedule and Procedure for Adoption and Implementation of Contingency Measures 

EPD will, in the event of I) a Tier II trigger condition or 2) a Tier I condition in which EPD has 

determined that a Tier II condition is likely to occur, conduct a comprehensive study to determine 

whether or not contingency measures are required for the maintenance of the PM2.5 standard. 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 comprehensive analysis, based on qualityassured ambient data, will examine: 

45 of 54 
Atlanta PM2.s NonattainmentArea 

Redesignation Request and Maintenance Plan 

• the severity of the trigger condition; 

• the meteorological conditions (in the case of an ambient concentration trigger) 

associated with the trigger condition; 

• potential contributing local emissions sources; 

• potential contributing emissions resulting fi-om regional or long-range transpmt; 

• the geographic applicability of possible contingency 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) S02 controls]; and 

• current and recently-identified control technologies. 

The comprehensive study will be completed and submitted to EPA as expeditiously as practical but 

no later than nine months after the Tier I or Tier II trigger is activated. If EPD determines, through 

the comprehensive study, that contingency measures are required for maintenance of the standard, 

the appropriate corrective measures will be adopted and implemented within I 8 to 24 months after 

the Tier I or II trigger occurs. These control measures which will continue to produce substantial 

reductions in fine pmticulate matter and its precursors in excess of what is relied upon in this 

maintenance plan, include the Georgia Multipollutant Rule, which is described in Section 2.3.2.1 of 

this maintenance plan, as well as diesel engine retrofit, replacement, and repowering programs and 

truck stop electrification programs which are currently being implemented by Georgia EPD. 

If the study determines that additional measures are required, rules will be adopted no later thm1 18 

months following the date on which the Tier I or Tier II trigger is activated. Selection of measures 

will take into consideration the ease of implementation as well as technical and economic feasibility. 

If it is determined that adoption and implementation 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 trigger 

condition, EPD will evaluate those measures as specified in Section I 72 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, a11d that measure/control is determined to 

be adequate, additional local controls may be unnecessmy. Under Section 175A(d), the minimum 

requirement for contingency measures is the implementation of all measures that were contained in 

the SIP before the redesignation. Currently, all such measures are in effect for the Atlanta NAA; 

however, an evaluation of those measures, such as RACT, can be performed to determine those 

measures are adequate or up-to-date. h1 addition to those identified in Section 3 .2.2, contingency 

measure(s) will be selected from the following types of measures or fi·om any other measure deemed 

appropriate m1d effective at the time the selection is made: 

• Reasonably Available Control Measures (RACM) for sources of S02 and PM25; 

• Reasonably Available Control Technology (RACT) for point sources of S02 and PM2.s; 

• Expansion ofRACM/RACT to area(s) oftranspmt within the State; 

• Mobile source measures; and 

• Additional S02 and/or PM2.s reduction measures yet to be identified. 

46 of 54 
Atlanta PM2.s NonattainmentArea 

Redesignation Request and Maintenance Plan 

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 fi'om interested and affected persons (stakeholders) in the area prior to 

selecting appropriate contingency measures. No contingency measure will be implemented without 

providing the opportunity for full public participation. This process will include issuance of notices, 

an opportunity for public hearing, and other measures required by Georgia law. 

47 of 54 
Atlanta PM2.s NonattainmentArea 

Redesignation Request and Maintenance Plan 

4.0 Motor Vehicle Emissions Budget 

The transpmtation conformity rule (40CFR93.100- 40CFR93.129) ensures that projects and plans 

funded by the Federal Highway Administration and the 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 established for the last year of the plan's maintenance 

period. The rule, at 40CFR93.124(a), describes a motor vehicle emissions budget as " ... the 

implementation plan's estimate of future [motor vehicle] emissions." Such budgets establish caps on 

motor vehicle emissions; projected emissions from transpottation plans and programs must be equal 

to or less than these caps for a positive conformity determination to be made. Transpmtation 

conformity determinations are required for non-exempt federally-funded highway and transit 

projects before they are funded and approved and for transpmtation plans and transpmtation 

improvement programs. 

4.1 Pollutants 

For the Atlanta area, MVEBs will be set for direct PM2.5 and NOx only. 40 CFR Patts 93.119(f)(7) 

through (10) identify the PM25 pollutants which must be analyzed for transpmtation conformity 

purposes. These patts of the rule are listed below: 

§119(/)(7)- PM1.5 in PM1.s areas; 

§119(/)(8) - Reentrained road dust in PM.5 areas only if the EPA [Environmental Protection Agency} 

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 significant contributor to the PM. 5 nonattainment 

problem and has so notified the MPO and DOT [Department of1i·ansportationj; 

§119(/)(9)- NOx [nitrogen oxides} in PM1.s areas, unless the EPA Regional Administrator and the 

director of the State air agency have made a finding that emissions of NO, from within the area are 

not a significant contributor to the P M1_5 nonattainment problem and has so notified the MPO and 

DOT; and 

§119(/)(10)- VOC, S01 and/or ammonia in PM1.5 areas if the EPA Regional Administrator or the 

director of the State air agency has made a finding that any of such precursor emissions jrmn within 

the area are a significant contributor to the PM1.5 nonattainment problem and has so notified the 

MPO and DOT. 

Primary, or direct, PM25 emissions must be considered for all transportation conformity regional 

emissions analyses. For the Atlanta area, NOx must also be considered since EPA has not approved 

Georgia EPD's finding that NOx is not a significant contributor to the PM25 nonattainment problem 

in the Atlanta area. None of the other pollutants identified (reentrained road dust, VOC, and 

ammonia) above have been detetmined by EPA or Georgia EPD to be significant contributors to PM 

nonattainment in the Atlanta area. S02 from coal combustion is significant, but levels of S02 

emissions from mobile sources are very low and, therefore, not significant for transportation 

confonnity purposes. 

48 of 54 
4.2 Methodology 

Atlanta PM2.s NonattainmentArea 

Redesignation Request and Maintenance Plan 

In preparation of this Atlanta area PM25 Maintenance Plan, EPD worked closely with the Georgia 

Depattment of Transportation (GDOT) and the Atlanta Regional Commission (ARC) to develop the 

estimates of mobile source emissions for the Atlanta nonattainment area. ARC is the metropolitan 

planning organization (MPO) for the Atlanta area. Mobile source inventories for 2024 were 

developed using the latest available planning assumptions, the most recent travel demand model, 

EPA's latest motor vehicle emission factor model, and vehicle population and age distributions 

developed from registration data obtained fi·om R.L. Polk & Company. The methodology used to 

calculate the highway mobile source emissions on which the 2024 MVEBs are based is discussed 

below. 

Emissions fi·om motor vehicles were estimated as a sum of products of vehicle activity measures and 

vehicle emissions factors. Vehicle activity measures (e.g. vehicle miles traveled, or VMT) are 

determined fi·om a county-specific travel demand model. Vehicle emissions factors are determined 

from a motor vehicle emissions model. See Appendices C-7 for more details on the development of 

the travel demand model and the detennination of emissions factors. 

The MOVES20 I Oa motor vehicle emission model was used to calculate 2024 emission factors with 

all currently-known 2024 mobile source control rules in place. The MOVES model was run in 

Inventmy Mode. The emission factors reflect all federal controls, e.g., the Federal Motor Vehicle 

Control Program including Tier I and (beginning with 2006 models) Tier 2 tailpipe standards; and 

the National Low Emission Vehicle program. MOVES201 Oa produces three sets of emission factors 

per run: 

• rate per distance; 

o rate per vehicle; and 

• rate per profile. 

Of these three types of emission factors, the first is multiplied by VMT, and the second two factors 

are multiplied by vehicle population. Note that rate-per-profile emissions (i.e., vapor venting) are 

not applicable to PM2_5 modeling. 

The ARC travel demand model is developed and maintained by GDOT. Inputs to the model are 

socioeconomic data and the highway network that consists of roadway segments (links) and 

intersections (nodes). Outputs include vehicle activity, number of trips, vehicle population, and other 

data. The use of a county-specific travel demand model for transportation conformity calculations is 

consistent with the transpottation conformity rule at 40CFR93.122(b) and (d), which requires a 

network-based travel model emissions estimation methodology 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 ARC. 

Section 93.105(b) of the Transportation Conformity Rule and Sections 106(g) and 106(h) of 

Georgia's transpottation conformity SIP require interagency consultation for SIP development. 

Accordingly, a detailed listing of the procedures and planning assumptions used for the regional 

emissions analysis supporting development of the MVEB was presented to the Atlanta interagency 

consultation committee for review and was approved on August 26, 2011. The assumptions used to 

49 of 54 
Atlanta PM2.s Non attainment Area 

Redesignation Request and Maintenance Pkm 

develop Atlanta's conforming Long Range Transpmtation Plan and Transpmiation Improvement 

Program were also used to develop the network and emissions for this maintenance plan MVEB. 

4.3 Motor Vehicle Emissions Budgets aud Safety Margins 

The projected 2024 on-road motor vehicle emissions for direct PM25 and NOx are 1642 and 35,272 

tons, respectively. A budget for S02 is not required. On-road emissions of S02 are considered to be 

"de-minimis" (70FR 24283); therefore, no budget is necessary. The on-road mobile emissions, 

emissions budgets, and safety margins are presented in Table 4-1. A safety mm·gin is necessmy to 

accommodate the variabilities or worst-case scenarios that can occur due to future planning 

assumptions. 

The worst-case daily motor vehicle emiSSIOns projection for PM25 is 38.9 percent above the 

projected 2024 on-road emissions. In a worst-case scenario, the needed annual safety margin for the 

MVEB would be 639.0 tons resulting in an overall MVEB of2,281.2 tons per year. 

The worst-case daily motor vehicle emissions projection for NOx is 26.0 percent above the projected 

2024 on-road emissions. In a worst-case scenario, the needed annual safety margin for the MVEB 

would be 9,157.7 tons resulting in an overall MVEB of 44,429 tons per year. 

Table 4-1. 2024 Motor Vehicle Emissions, Emissions Budgets, and Safety Margins 

.. 

Pollutant. Projected 2024 Safety Margin Safety Margin MVEB with Safety 

On-Road Allotted to MVEB Allotted to Margin (tons) 

Emissions (%) MVEB(tons) 

(tons) 

PM25 1642 39 639 2281 

NOx 35,272 26 9158 44,429 

50 of 54 
5.0 Conclusion 

Atlanta PM2.s NonattainmentArea 

Redesignation Request and Maintenance Plan 

Section 107(d) of the CAA states that an area can be redesignated to attainment if the following 

conditions are met: 

I. The EPA has detennined that the NAAQS has been attained. 

2. The applicable implementation plan has been fully approved by EPA under Section II O(k). 

3. The EPA has determined that the improvement in air quality is due to permanent and 

enforceable reductions in emissions. 

4. The state has met all applicable requirements for the area under Section II 0 and Patt D. 

5. The EPA has fully approved a maintenance plan, including a contingency plan, for the area 

as required by CAA Section 175A. 

Table 5-1. Summary of Projected S02 Emissions- Total of All Sectors (tons) 

2008 

2014 2017 2020 2024 

Source attainment 

(tons) (tons) (tons) (to us) (tons) 

. 

Point - total 413,478 172,170 51,697 52,601 53,803 

Area- total 10,237 10,557 10,717 10,884 11,107 

Non-road - total 1,675 1,516 1,437 1,553 1,708 

Onroad 725 629 581 533 469 

Total 426,115 184,873 64,433 65,572 67,088 

51 of 54 
Atlanta PM2.s NonattainmentArea 

Redesignation Request and Maintenance Plan 

Table 5-2, Summary of Projected NOx Emissions- Total of All Sectors (tons) 

.. 

2008 

2014 2017 2020 2024 

Source attainment 

.(tons) (tons) (tons) (tons) (tons) . 

Point - total 80,785 45,489 27,867 28,535 29,423 

Nonpoint- total 21,193 23,531 24,698 25,916 27,537 

Non-mad -total 40,599 34,086 30,835 29,747 28,298 

On mad 128,955 93,806 76,258 58,675 35,272 

Onroad Safety Margin 9,158 

Total 271,531 196,912 159,659 142,873 129,688 

Table 5-3. Summary of Projected PM2.

5 Emissions- Total of All Sectors (tons) 

2008 2014 2017 2020 2024 

Source attainment 

(tons) (tons) (tons) (tons) (tons) . 

Point - total 5,637 4,541 3,993 4,120 4,288 

Nonpoint- total 35,686 40,052 42,232 44,072 46,520 

Non-road -total 2,827 2,360 2,127 1,967 1,755 

On road 4,662 3,530 2,963 2,397 1,642 

Onroad Safety Margin 639 

Total 48,811 50,482 51,316 52,556 54,844 

52 of 54 
Atlanta PM2.s NonattainmentArea 

Redesignation Request and Maintenance Plan 

The supporting documentation to show that the above conditions have been met for the Atlanta 

area is contained in this document. Based on the 2008-2010 monitored design value for the Atlanta 

nonattainment area, EPA has published in the Federal Register its final rule that the nonattainment 

area has attained the 1997 annual average PM2.5 National Ambient Air Quality Standard (NAAQS). 

The maintenance demonstration in this document shows that, based on comparison of projected 

emissions to attainment year emissions, emissions are expected to stay at or below levels 

commensurate with attaining air quality through the year 2024 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 PM2.5 emissions. This document also contains provisions for 

contingency measures should emissions levels or ambient concentrations rise unexpectedly. EPA's 

concurrence that the improvement in the Atlanta area's air quality is due to permanent and 

enforceable reductions in emissions and EPA's approval of this document will satisfY Items 3 and 5 

above. Therefore, Georgia EPD requests that tbe Atlanta area be redesignated fi·om nonattainment to 

attainment with respect to the 1997 annual NAAQS for fine pmticulate matter. In addition, 2024 

MVEBs have been presented for onroad mobile emissions of direct PM2.s and NOx. These emissions 

budgets are required by EPA's transportation conformity rule as tools for ensuring conformance of 

highway and transit plans with air quality SIPs and maintenance plans. 

53 of 54 
6.0 References 

Atlanta PM2.s NonattainmentArea 

Redesignation Request and Maintenance Plan 

State of Georgia, Rules for Air Quality Control, Chapter 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 201 I, Docket ID No. EPA-HQ-OAR-2009-0491-4140. 

USEPA, "Approval, and Promulgation of Air Quality Implementation Plans; Indiana; Redesignation 

of the Evansville Area to Attainment of the Fine Particulate Matter Standard'; proposed mle, 76 FR 

29695. 

US EPA, "Clean Data Policy for the Fine Patticle National Ambient Air Quality Standards," 

Memorandum fi·om Stephen Page, December 14, 2004. 

USEPA, "Determination of Attaining Data for the 1997 Annual Fine Patticulate Standard; Atlanta, 

Georgia, Final Rule"; 76 FR 76620. 

USEPA, "Federal Implementation Plans: Interstate Transport of Fine Particulate Matter and Ozone 

and Correction of SIP Approvals" [a.k.a. "Cross-State Air Pollution Rule"]; finalmle, 76 FR 48208. 

USEPA, National Emissions Inventmy: Inventory Years 2005, and 2008. 

USEPA, "Procedures for Processing Requests to Redesignate Areas to Attainment," Memorandum 

fi·om John Calcagni, September 14, 1992. 

54 of 54