Georgia Department of Natural Resources 

;Sfp 14 2012 

Ms. Gwendolyn Keyes Fleming 

Regional Administrator 

U.S. EPA, Region 4 

61 Forsyth Street, S.W. 

Atlanta, Georgia 30303-3104 

Environmental Protection Division • Air Protection Branch 

4244 International Parkway • Suite 120 • Atlanta • Georgia 30354 

404/363-7000 • Fax: 404/363-7100 

Mark Williams, Commissioner 

Judson H. Turner, Director 

RE: Maintenance Plan and Redesignation Request for the Georgia Portion of the 

Chattanooga 1997 Annual PM2.s Nonattainment Area 

Dear Ms. Fleming: 

With this letter, the Georgia Environmental Protection Division (EPD) is submitting for approval 

and incorporation the proposed revisions to Georgia's State Implementation Plan (SIP) to 

include a plan, consistent with §175A of the Clean Air Act, to provide for maintenance of the 

1997 Annual PM25 National Ambient Air Quality Standard (NAAQS) in Georgia's portion 

(Catoosa and Walker Counties) of the Chattanooga nonattainment area. This submittal also 

serves as a request that the Chattanooga Nonattainment Area be redesignated as an area 

attaining the 1997 Annual PM25 NAAQS upon approval of the Georgia, Alabama, and 

Tennessee Maintenance Plans for the entire Chattanooga 1997 Annual PM2.5 Nonattainment 

Area. 

The Chattanooga 1997 Annual PM2.5 Nonattainment Area is comprised of portions of three 

contiguous states; Hamilton County in Tennessee, Catoosa and Walker Counties in Georgia 

and a portion of Jackson County in Alabama. Redesignation of this area is contingent on the 

approval of the maintenance plans from all three states. Each plan must demonstrate the 

standard is maintained through the year 2025 based on an emissions analysis compared to the 

attainment year of 2007. The development of the maintenance plan for the Georgia portion of 

this area has been coordinated with the Alabama Department of Environmental Management, 

the Tennessee Department of Environment & Conservation, and the Chattanooga/Hamilton 

County Air Pollution Bureau. At the time of this submittal, the plans and emissions analysis for 

the Alabama and Tennessee portions of the area are not yet complete and cannot be 

substantively addressed by this submission. 

On May 31, 2011, EPA published a final rule determining that the Chattanooga area had 

attained the 1997 fine particulate matter standards. On September 8, 2011, EPA published a 

final rule making a determination that the Chattanooga Area had attained the 1997 annual PM2.5 

standard prior to the April 5, 2010 attainment date. Georgia EPD withdrew its previous 

submittal of nonattainment planning documents for the Chattanooga area in a letter to EPA 

dated June 29, 2011. The emissions inventory submitted with the October 16, 2009 SIP 

revision to comply with the Clean Air Act requirements of §172 for nonattainment areas was not 

affected by the June 29, 2011 request. 
Ms. Gwendolyn Keyes Fleming 

Page Two 

SEP 14 ZOI! 

The public notice for the proposed SIP revision was advertised using the EPD Air Protection 

Branch listserv mailing list for public notices. Attached to this transmittal letter is EPD's 

response to the comments received during the public comment period. 

As required by the federal SIP-processing regulations, we have enclosed certifications that the 

required public notices were provided and that a public hearing was held. We have also 

enclosed the administrative and technical support checklists to satisfy the SIP submittal 

completeness criteria. This submittal includes one paper copy of each of the relevant 

documents and a compact disk with an electronic version of the documents. The electronic 

version is an exact duplicate of the paper copy. 

We look forward to your review and approval of these revisions. Should you or your staff have 

any questions, please feel free to contact Jimmy Johnston at (404) 363-7014. 

Si~qerely, 

t /:-. d // 

1/ 

~6dson H. Turner 

birector 

JHT:JK:klc 

Enclosures: 

Maintenance plan (one paper and one CD) 

- Administrative checklist 

- Technical checklist 

Certification of public hearing 

- Copy of public notice 

- Response to comments memo 

Copy w/o encl: 

Scott Davis, EPA Region 4 

Lynorae Benjamin, EPA Region 4 

James A. Capp, Branch Chief, EPD Air Protection Branch 
Chattanooga PM2.5 Nonattainment Area- Redesignation Request and Maintenance Plan 

Administrative Materials for SIP submittal dated: August 31, 2012 

1. A formal letter of submittal from the Governor or his designee, requesting EPA 

approval of the plan or revision thereof (hereafter "the plan"). 

The cover letter transmitting this proposed maintenance plan is the forma/letter of 

submission. 

2. Evidence that the State has adopted the plan in the State code or body of 

regulations; or issued the permit, order, consent agreement (hereafter "document") 

in final form. That evidence shall include the date of adoption or final issuance as 

well as the effective date of the plan, if different from the adoption/issuance date. 

The State promulgated Georgia Rules 391-3-1.02(2)(sss) and (uuu), which require 

S02 controls and establish minimum S02 control efficiencies on multiple Georgia 

electric generating units. These rules are a part of the subject maintenance plan. 

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

and implement the plan. 

The Georgia Air Quality Act, Article 1: Air Quality (0. C. G.A. 12-9, et. seq.) 

provides the necessary legal authority under State law to adopt and implement the 

revisions. The Act, in its entirety, is located at http:llwww.lexisnexis.com/hottopics/gacode/ under Title 12, Chapter 9, Article 1. 

4. A copy of the actual regulation, or document submitted for approval and 

incorporation by reference into the plan, including indication of the changes made 

to the existing approved plan, where applicable. The submittal shall be a copy of 

the official State regulation/ document signed, stamped, dated by the appropriate 

State official indicating that it is fully enforceable by the State. The effective date 

of the regulation/document shall, whenever possible, be indicated in the document 

itself. 

Enclosed is a copy ofthe affected Maintenance Plan, dated August 31, 2012, for 

approval and incorporation into the plan. This maintenance demonstration plan 

maintains all previously-adopted control measures contained in all previouslysubmitted attainment demonstration submittals. 

5. Evidence that the State followed all of the procedural requirements of the State's 

laws and Constitution in conducting and completing the adoption/issuance of the 

plan and compilation of public comments and the State's response thereto. 

The procedural requirements associated with this plan and public comment period 

are included in the submittal to EPA. 

6. Evidence that public notice was given of the proposed change consistent with 

procedures approved by EPA, including the date of publication of such notice and 

Certification that public hearings(s) were held in accordance with the information 

provided in the public notice and the State's laws and constitution, if applicable. 

Documentation for the public notice (posted July 2, 2012), hearing (held August 

14, 2012) and comment requirements is included in the submittal to EPA. 
Chattanooga PM2.5 Nonattainment Area- Redesignation Request and Maintenance Plan 

Technical Support for SIP Submittal dated: August 31, 2012 

1. Identification of all regulated pollutants affected by the plan. 

The proposed Maintenance Plan covers emissions of primary PM2.5 and of S02 

and NOx, which are PM2.5 precursors 

2. Identification of the locations of affected sources including the EPA 

attainment/non-attainment designation of the locations and the status of the 

attainment plan for the affected areas(s). 

The Maintenance Plan is applicable to the Chattanooga Annual PM2.5 

Nonallainment Area in Georgia. 

3. Quantification of the changes in plan allowable emissions from the affected 

sources; estimates of changes in current actual emissions from affected sources 

or, where appropriate, quantification of changes in actual emissions from affected 

sources through calculations of the differences between certain baseline levels 

and allowable emissions anticipated as a result of the revision. 

Refer to the maintenance plan. 

4. The State's demonstration that the national ambient air quality standards, 

prevention of significant deterioration increments, reasonable further progress 

demonstration, and visibility, as applicable, are protected if the plan is approved 

and implemented. For all requests to redesignate an area to attainment for a 

national primary ambient air quality standard, under section 107 of the Act, a 

revision must be submitted to provide for the maintenance of the national primary 

ambient air quality standards for at least 10 years as required by section 175A of 

the Act. 

The NAAQS will be protected through 2025 ifthis revision is approved and 

implemented. 

5. Modeling information required to support the proposed revision, including input 

data, output data, models used, justification of model selections, ambient 

monitoring data used, meteorological data used, justification for use of offsite data 

(where used), modes of models used, assumptions, and other information relevant 

to the determination of adequacy of the modeling analysis. 

Refer to the maintenance plan. 

6. Evidence, where necessary, that emission limitations are based on continuous 

emission reduction technology. 

The State and Federal control measures for point sources, onroad mobile sources, 

and nonroad mobile sources that are documented in Section 2 ofthe maintenance 

plan are all based on continuous emission reduction technology. 
Chattanooga PM2.5 Nonattainment Area- Redesignation Request m1d Maintenance Plm1 

7. Evidence that the plan contains emission limitations, work practice standards and 

recordkeeping/reporting requirements, where necessary, to ensure emission 

levels. 

Section 2 of the maintenance plan documents Federal and State measures that 

have contributed to permanent and enforceable emissions reductions in the 

Chattanooga Area and that have resulted in attainment of the annual PM2. 5 

standard. Section 3 of the maintenance plan demonstrates that, with the Federal 

and State measures in place, emission levels will be kept at levels sufficient to 

maintain attainment of the standard through the year 2025. 

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

in practice. 

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

Agreement. 

9. Special economic and technological justifications required by any applicable EPA 

policies, or an explanation of why such justifications are not necessary. 

No special economic or technological justifications are required for this proposed 

Maintenance Plan. 
Georgia Department of Natural Resources 

Environmental Protection Division, Air Protection Branch 

4244 International Parkway, Suite 120, Atlanta, Georgia 30354 

Phone:404/363-7000;Fax:404/363-7100 

Mark Williams, Commissioner 

Judson Turner, Director 

CERTIFICATE OF PUBLIC HEARING 

I do hereby certify that a public hearing was held on August 14,2012, concerning proposed 

amendments to Georgia's Portion of the Chattanooga PM2.5 Maintenance Plan. 

A public notice posted at air-notices@listserv.dnr.state.ga.us for review and comments on 

July 2, 2012. 

Ja s P. Jo nston, Manager 

P nning and Support Program 

Date 
1(7i9i2of2)L)'nne Collier~ air-notices-Di98St,Vol69, lssu_e i ------------·--· -------- - --

From: 

To: 

Date: 

Subject: 

<air -notices-req uest@listserv. dnr. state. ga. us> 

<air -notices@listserv .dn r. state. ga. us> 

7/2/20121:18 PM 

air-notices Digest, Vol69, Issue 1 

Send air-notices mailing list submissions to 

air -notices@! istserv. d n r. state. ga. us 

To subscribe or unsubscribe via the World Wide Web, visit 

http://listserv.dnr.state.ga.us/mailman/listinfo/air-notices 

or, via email, send a message with subject or body 'help' to 

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You can reach the person managing the list at 

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When replying, please edit your Subject line so it is more specific 

than "Re: Contents of air -notices digest..." 

Today's Topics: 

1. EPD Public Advisory for the Week of June 25, 2012 (PA0612-4) 

(air -notices@! istserv .dn r. state. ga. us) 

2. Revisions to Georgia?s State Implementation Plan 

(air-notices@listserv.dnr.state.ga.us) 

Message: 1 

Date: Wed, 27 Jun 2012 14:04:52-0400 

From: air-notices@listserv.dnr.state.ga.us 

Subject: [Georgia Air Branch public notices & advisories] EPD Public 

Advisory for the Week of June 25, 2012 (PA0612-4) 

To: <air -notices@listserv. dnr.state. ga. us> 

Message-ID: <4FEB1303.F088.000C.O@dnr.state.ga.us> 

Content-Type: texVplain; charset="us-ascii" 

EPD PUBLIC ADVISORY 

GEORGIA AIR PROTECTION BRANCH 

SIP PUBLIC ADVISORIES 

The following applications have been received for Air Quality Permits. 

These applications are presently under review. Any comments should be received by 27-July-2012. 

NEWTON 

Facility Name: Pactiv Corp 

Application No: 21239 

Facility Address: 8170 Alcovy Road, Covington, 30014 (Newton). 

EPD Notice Type: Permit- Application. 

Description of Operation: Extruded polystyrene foam production. 

____ _F'<lge 1 I 

Reason for Application: Changes to the cooling system for extrusion lines and replacement of extruder 

components. 
[Tl/9/2012) Lynne Collier:air-noUces[)igest, Vol69, Issue 1 __ _ 

TOOMBS 

Facility Name: LDH/ECI Energy LLC 

Application No: 21243 

Facility Address: U.S. Highway 1, Lyons, 30436 (Toombs). 

EPD Notice Type: Permit- Application. 

Description of Operation: Charcoal Bio Fuel Manufacturing Facility. 

-----

Reason for Application: Construction and operation of a charcoal bio fuel manufacturing facility. 

For additional information, contact Eric Cornwell, Program Manager, 

Stationary Source Permitting Program, Air Protection Branch, 

4244 International Parkway, Suite 120, Atlanta, Georgia 30354, 

(404) 363-7000. 

NOTICE OF DRAFT TITLE V OPERATING PERMITS AND PERMIT MODIFICATIONS 

GEORGIA ENVIRONMENTAL PROTECTION DIVISION 

AIR PROTECTION BRANCH 

4244 INTERNATIONAL PARKWAY, SUITE 120, ATLANTA, GA 30354 

The Georgia Environmental Protection Division announces its intent to 

issue initial Title V Operating Permits, Title V Significant 

modifications, Title V Operating Permit Renewals, and/or other Title V 

Permit proceedings for the following facilities. The deadlines for 

submitting comments and requesting a public hearing are specified for 

each facility. 

RENEWAL TITLE V OPERATING PERMITS 

HALL 

Facility Name: Milliken & Co New Holland Plant 

Application No: 20597 

Facility Address: 1750 Jesse Jewell Pkwy, Gainesville, 30501 (Hall). 

EPD Notice Type: Permit- Proposed. 

Description of Operation: Textile Mill. 

Comment period/deadline for public hearing request expires on: July 30, 2012. 

ADDITIONAL INFORMATION: The draft permits and permit amendments and 

all information used to develop the draft permits and permit amendments 

are available for review. This includes the application, all relevant 

supporting materials and all other materials available to the permitting 

authority used in the permit review process. This information is 

available for review at the office of the Air Protection Branch, 

4244 International Parkway, Atlanta Tradeport -Suite 120, Atlanta, Georgia 30354. 

Copies of the draft permits or permit amendments, narratives, 

application summaries, and (in most cases) permit applications are also 

available at our Internet site, www.georgiaair.org. Also 

available at this Internet site is a copy of the public notice, as it 

will appear in the legal organ of the county where the facility is 

located. 

If a permit application is not available at our Internet site, the 

public notice will indicate where a copy of these documents will be 

available at a location near the facility. 

Page 2] 
[ (7/9/2012) LynneCollier- air-notices Digest,yol69, Issue 1 

Persons wishing to comment on a draft Initial Title V Operating Permit, 

Title V Significant modification, Title V Operating Permit Renewal, or 

other Title V Permit proceedings are required to submit their comments, 

in writing, to EPD at the above Atlanta Air Protection Branch address. 

Comments must be received by no later than the deadline indicated for 

the particular facility. (Should the comment period end on a weekend or 

holiday, comments will be accepted up until the next working day.) All 

comments received on or prior to the deadline will be considered by the 

Division in making its final decision to issue the Title V permit or 

permit amendment. 

Any requests for a public hearing must be made prior to the deadline 

indicated for the particular facility. A request for a hearing should 

be in writing and should specify, in as much detail as possible, the 

portion of the Georgia Rules for Air Quality Control or the Federal 

Rules which the individual making the request is concerned may not have 

been adequately incorporated. A public hearing may be held if the 

Director of the EPD finds that such a hearing would assist the EPD in a 

proper review of the facility's ability to comply with the Federal and 

State air quality regulations. 

For additional information, contact Eric Cornwell, Program Manager, 

Stationary Source Permitting Program, Air Protection Branch, 

4244 International Parkway, Suite 120, 

Atlanta, Georgia 30354, (404) 363-7000. 

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Message: 2 

Date: Mon, 02 Jul2012 13:14:52 -0400 

From: air -notices@listserv.dnr.state.ga. us 

Subject: [Georgia Air Branch public notices & advisories] Revisions to 

Georgia?s State Implementation Plan 

To: <air-notices@listserv. dnr. state.ga. us> 

Message-ID: <4FF19ECF.F489.000C.O@dnr.state.ga.us> 

Content-Type: text/plain; charset="utf-8" 

DEPARTMENT OF NATURAL RESOURCES 

ENVIRONMENTAL PROTECTION DIVISION 

NOTICE OF PUBLIC HEARING AND PROPOSED AMENDMENTS 

TO GEORGIAn;;Os STATE IMPLEMENTATION PLAN 

TO ALL INTERESTED PERSONS AND PARTIES: 

Notice is hereby given that, pursuant to the authority set forth below, 

the Environmental Protection Division (hereinafter, I<;;£EPDI<;;¥) of the 

Georgia Department of Natural Resources proposes amendments to 

Georgiar<;;Os State Implementation Plan (SIP). The proposed revision 
[(7/9/2012) Lynne Collier- aii-~noticesDigest, Vol 69,Tssue 1 

---

is described below: 

The proposed State Implementation Plan revision includes Georgia's 

request under the Clean Air Act that Georgian;Os portion of the 

Chattanooga annual PM2.5 nonattainment area (Catoosa and Walker 

Counties) be redesignated to attainment with respect to the 1997 

National Ambient Air Quality Standard (NAAQS) for PM2.5 as well as 

Georgian;:Os plan to maintain attainment of the 1997 annual PM2.5 

standard in Georgian;:Os portion of the Chattanooga area. 

This notice is being provided to all persons who have requested in 

writing that they be placed on a notification list. The proposed SIP 

revision may be viewed at 

http:/lwww.georgiaair.org/airpermitlhtml/planningsupportlregdev/sips_and_revisions/sips_and_revisions.h 

tm 

or during normal business hours of 8:00 a.m. to 4:30 p.m. at the 

Georgia Environmental Protection Division, Air Protection Branch, 4244 

International Parkway, Suite 120, Atlanta, Georgia 30354. Copies may 

also be requested by contacting the Air Protection Branch at 

404/363-7000 or the Environmental Protection Division Directori~Os 

Office at 1-888-373-5947. 

To provide the public an opportunity to comment upon and provide input 

into the proposed SIP revision, a public hearing will be held at 6:00 

p.m. on August 14, 2012, at the Walker County Civic Center, 10052 North 

Highway 27, Rock Spring, Georgia 30739. At the hearing, anyone may 

present data, make a statement, comment or offer a viewpoint or argument 

either orally or in writing. Lengthy statements or statements of a 

considerable technical or economic nature, as well as previously 

recorded messages, must be submitted in writing for the official record. 

Oral statements should be concise. 

Written comments are welcomed. To insure their inclusion in EPD's 

f1nal submission of the SIP revision to EPA, written comments should be 

received by close of business on August 21, 2012. Written comments may 

be emailed to EPDComments@dnr.state.ga.us or sent via regular mail 

addressed to: Branch Chief, Air Protection Branch, 4244 International 

Parkway, Suite 120, Atlanta, Georgia, 30354. 

The proposed SIP revision is proposed pursuant to authority contained 

in Georgia Air Quality Act (O.C.G.A. Section 12-9-1 et. seq.). For 

further information, contact the Air Protection Branch at 404/363-7000. 

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