# Georgia Department of Natural Resources

;Sfp 

# 142012

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 ofthe Chattanooga 1997Annual PM 2

### .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 14ZOI!

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 ofthe paper copy. We look forward to your review and approval ofthese revisions. Should you or your staff have any questions, please feel free to contact Jimmy Johnston at (404) 363-7014.

### Si~qerely,



# t/:-. d
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# 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 JamesA. Capp, Branch Chief, EPD Air Protection Branch

### ChattanoogaPM2.5 NonattainmentArea- RedesignationRequest and MaintenancePlan

Administrative Materials for SIP submittal dated: August 31, 2012 

### 1. A formal letter of submittal from the Governor or his designee, requesting EPA approval ofthe plan or revision thereof (hereafter "the plan"). The coverlettertransmitting this proposedmaintenance 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 ofthe plan, ifdifferent from the adoption/issuance date. The State promulgated Georgia Rules 391-3-1.02(2)(sss) and (uuu), which require S0 2controls andestablish minimum S02 control efficiencies on multiple Georgia electric generating units. These rules are apart ofthe subjectmaintenance plan. 

### 3. Evidence that the State has the necessary legal authority under State law to adopt and implement the plan. The Georgia Air QualityAct, Article 1: Air Quality 

### (0.

### C. G.A. 12-9, et. seq.) provides the necessarylegal authorityunderState law to adoptandimplement the revisions. The Act, in its entirety, is locatedathttp:llwww.lexisnexis.com/hottopics/gacode/under Title 12, Chapter9, Article 1. 

### 4. A copy ofthe actual regulation, or document submitted for approval and incorporation by reference into the plan, including indication ofthe 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 ofthe regulation/document shall, whenever possible, be indicated in the document itself. Enclosedis a copy ofthe affectedMaintenance Plan, datedAugust 31, 2012, for approval andincorporation into the plan. This maintenance demonstration plan maintains allpreviously-adoptedcontrolmeasures containedin allpreviouslysubmittedattainment demonstration submittals. 

### 5. Evidence that the State followed all ofthe procedural requirements of the State's laws and Constitution in conducting and completing the adoption/issuance ofthe plan and compilation of public comments and the State's response thereto. The proceduralrequirements associated with this plan andpublic commentperiod are includedin the submittalto EPA. 

### 6. Evidence that public notice was given ofthe 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 forthe public notice (postedJuly

### 2, 2012), hearing (heldAugust 14, 2012) andcommentrequirements is included in the submittal to EPA.

### ChattanoogaPM2.5 NonattainmentArea- Redesignation Request and MaintenancePlan

Technical Supportfor SIP Submittal dated: August 31, 2012



### 1. Identification of all regulated pollutants affected by the plan. The proposedMaintenance Plan covers emissions ofprimary PM2.5 and ofS0 2 andNOx, which are PM2.5precursors 

### 2. Identification of the locations of affected sources including the EPA attainment/non-attainment designation ofthe locations and the status ofthe attainment plan for the affected areas(s). The Maintenance Plan is applicable to the Chattanooga AnnualPM2.5 NonallainmentArea in Georgia. 

### 3. Quantification ofthe changes in plan allowable emissions from the affected sources; estimates ofchanges in current actual emissions from affected sources or, where appropriate, quantification of changes in actual emissions from affected sources through calculations ofthe differences between certain baseline levels and allowable emissions anticipated as a result ofthe revision. Referto 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 ifthe 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 ofthe Act, a revision must be submitted to provide forthe maintenance ofthe national primary ambient air quality standards for at least 10 years as required by section 175A of the Act. The NAAQS willbe protectedthrough 2025 ifthis revision is approvedand 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 ofmodels used, assumptions, and other information relevant to the determination of adequacy ofthe modeling analysis. Referto the maintenance plan. 

### 6. Evidence, where necessary, that emission limitations are based on continuous emission reduction technology. The State andFederalcontrolmeasures forpointsources, onroadmobile sources, andnonroadmobile sources that are documentedin Section 2 ofthe maintenance plan are allbasedon continuous emission reduction technology.

### ChattanoogaPM2.5 NonattainmentArea- RedesignationRequest 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 ofthe maintenance plan documents Federal and State measures that have contributed to permanentandenforceable emissions reductions in the Chattanooga Area and thathave resultedin attainment ofthe annual PM2. 5 standard. Section 3 ofthe maintenance plan demonstrates that, with the Federal andState measures in place, emission levels will be kept atlevels sufficient to maintain attainment ofthe standardthrough the year2025. 

### 8. Compliance/enforcement strategies, including how compliance will be determined in practice. Enforcement willbe carried outas describedin the State/EPA Enforcement Agreement. 

### 9. Special economic and technological justifications required by any applicable EPA policies, or an explanation ofwhy such justifications are not necessary. No special economic ortechnologicaljustifications 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 MarkWilliams, Commissioner Judson Turner, Director



### CERTIFICATE OF PUBLIC HEARING

Ido herebycertifythat a public hearingwas held on August 14,2012,concerning proposed amendments to Georgia's Portion ofthe Chattanooga PM2.5 Maintenance Plan. A public notice posted at air-notices@listserv.dnr.state.ga.usfor reviewand comments on July 2, 2012.

Ja s P. Jo nston, Manager P nning and Support Program

Date1(7i9i2of2)L)'nne**Collier~** air-notices-Di98St,Vol69, lssu_e 

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From: To: Date: Subject: <air-notices-request@listserv.dnr.state.ga.us> <air-notices@listserv.dnr.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 nr.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 air-notices-request@listserv.dnr.state.ga.us You can reach the person managing the list at air-notices-owner@!istserv.dnr.state.ga.us When replying, please edityour Subject line so it is more specific than "Re: Contents ofair-notices digest..."
Today's Topics:

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

(air-notices@!istserv.dnr.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 ofJune 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 GEORGIAAIR PROTECTION BRANCH SIP PUBLIC ADVISORIES The following applications have been received forAir 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 ofOperation: Extruded polystyrene foam production. ____ _F'<lge 1 

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Reason forApplication: Changes to the cooling system for extrusion lines and replacement ofextruder components.[Tl/9/2012) Lynne Collier:air-noUces[)igest, Vol69, Issue 1

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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 ofOperation: Charcoal Bio Fuel Manufacturing Facility. -----

Reason for Application: Construction and operation ofa 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 intentto issue initial Title V Operating Permits, Title V Significant modifications, Title V Operating Permit Renewals, and/orother 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 ofOperation: 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 ofthe Air Protection Branch, 4244 International Parkway, Atlanta Tradeport -Suite 120, Atlanta, Georgia 30354. Copies ofthe draft permits or permit amendments, narratives, application summaries, and (in most cases) permit applications are also available atour Internet site, www.georgiaair.org. Also available atthis Internet site is a copy ofthe public notice, as it will appear in the legal organ ofthe county where the facility is located. Ifa permit application is not available at our Internet site, the public notice will indicate where a copy ofthese documents will be available ata location near the facility. 

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## 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 otherTitle 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 laterthan 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 ofthe Georgia Rules for Air Quality Control orthe Federal Rules which the individual making the request is concerned may not have been adequately incorporated. A public hearing may be held ifthe Director ofthe EPD finds that such a hearing would assist the EPD in a proper review ofthe 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<;;¥) ofthe Georgia Department of Natural Resources proposes amendments to Georgiar<;;Os State Implementation Plan (SIP). The proposed revision[(7/9/2012) LynneCollier-**aii-~noticesDigest,** Vol 69,Tssue 1

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is described below: The proposed State Implementation Plan revision includes Georgia's request underthe Clean AirAct that Georgian;Os portion ofthe 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 ofthe 1997 annual PM2.5 standard in Georgian;:Os portion ofthe 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 of8:00 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 ofa 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 ofthe 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 sentvia 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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