Regional Haze State Implementation Plan for Georgia
Administrative Materials for SIP submittal dated: November 10, 2009

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 plan is the formal letter ofsubmission. 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 adoption1issuance date. The State promulgated Georgia Rule 391-3-1.02(13) 

### - "CleanAir lnterstate Rule SO2 Trading Program". This rule adopts 40 CFR Part 96, SubpartsAAA through HHH by reference to implement the CAlR SO2 trading program. GA Rule 391-3-1- .02(2)(sss) requires SO2 controls (flue gas desulfurization) on coal-fired EGUs in Georgia. In addition, the following permits contain S02-limiting conditions for non-EGU facilities that implement the plan: Permit No. To be issued 263 1-099-0001-V-02-6

A copy of the Georgia Pacific Cedar Springs permit amendment has been included with this submittal. SIP amendments with copies of the relevant portions of the other permit amendments will be submitted as these permit amendments are finalized. Facility Georgia Pacific

To be issued To be issued

3. Evidence that the State has the necessary legal authority under State law to adopt and implement the plan. Enclosedis a copy of the Georgia Air Quality Act, Article I:Air Quality (0. C. G.A. 12-9, et. seq.) containing the necessary legal authority under State law to adopt and implement the plan. Unit(s) Power Boiler No. 4 ~runswick Cellulose Georgia Pacific

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 regulation1 document signed, stamped, dated by the appropriate State official indicating that it is fully enforceable by the State. The effective date of the regulationldocument shall, whenever possible, be indicated in the document itself. Enclosedis a copy of the affected plan, dated November 10, 2009, for approval and incorporation into the State lmplementation Plan. Power Boilers U500 and U501 Cedar Springs Interstate Paper International Paper Power Boiler PWOI Power Boiler 13Regional Haze State Implementation Plan for Georgia

Evidence that the State followed all of the procedural requirementsof 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. Enclosed as evidence that Georgia followed the procedural requirements in adopting this plan is the Certificate of Public Hearing and a memorandum dated December I I, 2009, from James Capp to Allen Barnes. These documents provide evidence that a public notice was issued, a public hearing was held, comments were received, and comments were addressed. 6. Evidence that public noticewas given of the proposed change consistent with procedures approved by EPA, including the date of publication of such notice and Certification that a public hearings(s)was held in accordancewith the information provided in the public notice and the State's laws and constitution, if applicable. Enclosedis a copy of the Notice of Public Hearing and the Certificate of Public Hearing.Regional Haze State Implementation Plan for Georgia

Technical Supportfor SIP Submittal dated: November 10,2009 1. ldentification of all regulated pollutants affected by the plan. The regulated pollutant addressed by the plan is S02. 2. ldentification of the locations of affected sources including the EPA attainmentlnon-attainmentdesignation of the locations and the status of the attainment plan for the affected areas(s). The plan affects Georgia sources of SO2 emissions that affect visibility at Class I areas in Georgia. Attainmenthon-attainment status is not relevant to the regional haze regulations. 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 Sections 76 and 7.7of theplan. 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. See Section 8.0 of the plan for a description of demonstration of reasonable further progress toward natural visibility in Georgia's Class I areas. 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. Section 5 of the plan discusses the selection ofmodels and data sets usedby the models. Section 6 is an evaluation of the performance of the models selected. 6. Evidence, where necessary, that emission limitations are based on continuous emission reduction technology. Where necessary, the rules adopted, including CAIR, requiring emission limitations are based on continuous emission reduction technology. 7. Evidence that the plan contains emission limitations, work practice standards and recordkeepinglreporting requirements, where necessary, to ensure emission levels. The required limits~controls for achievement of reasonable progress are documented in Sections 7.6.2, 7.6.4,and 7.7.3 of the plan. Further details are presented in Appendix M.Regional Haze State Implementation Planfor Georgia
8. Compliance/enforcementstrategies, 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. Not applicable.

# Georgia Department of Natural Resources Environmental Protection Division Air Protection Branch 4244 International Parkway Suite 120 Atlanta Georgia 30354 4041363-7000 Fax: 4041363-7100 Chris Clark, Commissioner

F.Allen Barnes, Director

CERTIFICATE OF PUBLIC HEARING


### I do hereby certify that a public hearingwas held on August 27, 2009, concerning a proposed revision to Georgia's Regional Haze State Implementation Plan. A public notice was published in major newspapers across the State: Savannah Morning News on July 29, 2009; Columbus Ledger Enquirer on July 29, 2009; Albany Herald on July 

### 31, 2009, Augusta Chronicle on July 29, 2009 and in the Atlanta Journal Constitution on July 

### 26, 2009, providing at least 30 days for review and comments. James P. Johnston, P.E. Program Manager Planning and Support Program 

# ////-3PY Dated: ~otzky&!$blic 

### - K. Lynne Collier

### YYry--- 

### AFFIDAVIT OF PUBLICATION SAVANNAHMORNING 

### NEWS STATE OF GEORGIA COUNTY 

### OF CHATHAM Personally appearcd before me, Alaina Williams-Fincher, to me known, who being sworn, deposes and says: That she is the ObituaryILegal Clerk for SoutheasternNewspaper Corporation, a Georgia corporation, doing business in Chatham County, 

### GA, under the tradename of Savannah Morning News, a daily newspaper published in said county; That he is authorized to make affidavits ofpublication on behalf of said published corporation; That said newspaper is of general circulation in said county and in the area adjacent thereto; That he has reviewed the regular editions of the Savannah Morning
: 

### News, published on:

, 

### 2009, 

### , 2009, and finds that the following advertisement, to-wit:

Appeared in each of said editions. I 

### (Deponent) Sworn to and subscribed before me A 

### This 

# LO day of ,2009 Notary tublic, ~hat$m County, Ga.

EUGENEJ. ON# Notary PuMic, Chalham CowlPy, 

### GA W Bymission Expires &wry B,Wte

### RECEIVED Geor$a FPD 

## AUG 

## 62009 Hazardous S~tes 

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that tfie '- -%* ich is affixed 11 its editions for
I

CLASSIFIED =GAL CLERK Sworn to and subscribed before 

# 5b me at Albany, Georgia this , 

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### NORTH 

### WASHINGTON 

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# State 

# of Georgia Department 

## ofNatural 

## Resources Environmental Protection 

### Division Air Protection Branch 

# Part 

# 70 Operating 

# Permit Amendment
PermitAmendment

### No.: 2631-099-0001-V-U2-6 Effective 

### Date: 

## JtlL 9 

## 3

## 2009 Facility 

### Name: 

### Georgia-Pacific Corporation, 

## Cedar Springs Operation Facility Address: 

### Highway 

### 273 West Cedar Springs, 

### Georgia 

### 39832 (Early 

### County) MailingAddress: P. 

### 0. Box 

### 44 Cedar Springs, Georgia 

### 39832 (Early County) ParentlHolding 

### Georgia-Pacific 

### Corpotation Company: FacilityAIRS Number: 04-1 

### 3-QW-OOOO~ In accordancewith the provisionsof the GeorgiaAir Qualify Act, O.C.G.A. Section 12-9-1, et seq and the Georgia Rules fw Air Quality Control, Chapter 391-3-1, adopted pursuant to and in effect under the Act. the Permittee describedabove is issued a construction permit for: Limit SO2 emissionsfrom Power Boilers No. 1 and 2 to 135 lbhreach and limit Recovery Boiler No. 3 SOZ emissions20 350 ppm

### on a dry basis corrected to 8 percent oxygen when firing black liquorto complywith BART regulations. This PermitAmendment sbllalso serve as a final amendment to the Part 70 Permit unless objected to bythe U.S. EPA or withdrawn by the Division. The Division wijl issue a letter when this Operating Permit amendment is finatized. This Permit Amendment is conditioned upon compliance with all provisions of The Georgia Air Quality Act, O.C.G.A. Section f2-9-1. et seq, the Rules, Chapter 391-3-t, adopted and in effect under that Act, or any other conditionof this Permit Amendment and Permit No. 2631-099-0001-V-02-0 Unless modifiedor revoked. this Permit Amendment expires upon issuance of the next Part70 Permitfor this source. This Perrnit Amendment may be subject to revocation, suspension, modification or amendmentby the Director for cause indudingevidence of noncompliancewith any of the above; 

### or for any misrepresentationmade in Application No. 18385 dated August 1, 2008;any other applications upon which this Permit Amendment or Permit No. 2631- 099-0501-V-02-0 are based; supporling data entered therein or attached thereto; or any subsequent submittal or supportingdata; or for any alterations affecting the emissionsfrom this source. This Permit Amendment is further subject to and conditioned upon the terns, conditions. limitations, standards. or schedules containedinor specifiedon the attached f 1 pages. 

# e Dire Environmental

### Protection DivisionTitle V Permit Amendment Georgia-Pacific Corporation- Cedar Springs Operation Permit No

. 

# .2631-099-000 1-V-02-6 

### Table 

### of Contents PART 1.0 1.3 PART 2.0 2.1 2.2 

### 2.3 2.4 PART 3.0 

### 3.1.1 3.2 PART 4.0 4.2 PART 5.0 5.2 PART 6.0 

### 6.1 6.2 PART 7.0 7.1 7.2 7.3 7.4 7.5 7.6 7.7 7.8 7.9 7.12 

### 7.13 7.14 

## ................................................................................................... FACILITY DESCRIPTION 

### I

. . 

### ProcessDescnptlon ofModification

........................................................................ 1 REQUIREMENTS PERTAINING TO THE ENTIRE FACILITY

## ............................................ I Facility Wide Emission Caps and Operating Limits

............................................................................ 

### 1 Facility Wide Federal Rule Standards

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

### Facility Wide SIP Rule Standards

....................................................................................................... 

### 1 Facility Wide Standards Not Covered by a Federal or 

### SIP Rule and Not Instituted as an Emission Cap or Operating Limit

........................................................................................................................ 1 REQUIREMENTS FOR EMISSION UNITS


## ......................................................................... 2



### ................................................................................................................... Additional Emission Units 2

. 

### . . . 

### Equipment Emlsslon Caps and OperatingLlmits



### ................................................................................ 3 REQUIREMENTS FOR TESTING

## ....................................................................................... 4



### ............................................................................................................ Specific Testing Requirements 4 REQUIREMENTS FOR MONITORING (Related to Data Collection)

## ................................ 5 

### Specific Monitoring Requirements



### ...................................................................................................... 5 OTHER RECORD KEEPINGAND REPORTING REQUIREMENTS

## .................................. 7 General Record Keeping and ReportingRequirements

............................................................. 

### .........

### 7 Specific Record Keeping and ReportingRequirements



### ....................................................................... 8 OTHER SPECIFIC REQUIREMENTS

## ............................................................................... I0 

### Operational Flexibility Associated with this Amendment

............................................................. 10 Off-Permit Changes Associated with this Amendment



### ..................................................................... 10 Alternative Requirements Associated with this Amendment



### ............................................................ 10



### .................... Insignificant Activities Associated with this Amendment 10 Temporary Sources Associated with this Amendment



### .................................................................... 10 Short-term Activities Associated with this Amendment



### ................................................................... 10 Compliance ScheduleProgressReports Associated with this Amendment



### ...................................... 10 Emissions Trading Associated with this Amendment



### ....................................................................... 10 Acid Rain Requirements Associated with this Amendment



### ............................................................. 10 Revocation of Existing Permits and 

### Amendments



### ............................................................................. 10 Pollution Prevention Associated with this Amendment



### ..................................................................... 11



### ...................................................................... Specific Conditions Associated with this Amendment 1 1b 

### TitleV Permit Amendment Georgia-Pacific Corporation- Cedar SpringsOperation PermitNo.: 2631 -099-0001-V-02-6 

### PART 1.0 

### FACILITY DESCRIPTION 1.3 

### Process Description of Modification Georgia-Pacific Corporation-Cedar Springs operation is making the following changes at the facility to comply with BART regulations.

PART 2.0 2.1 

### Limit SOz emissions from Power Boilers No. 1 and 2 to 135 Ibsh each for a block 24-hour averaging period. Emission will be reduced by scrubbant addition to the existing wet scrubbers, limestone addition to theboilers, orthe equivalent. Limit the SO2emissions from the recovery boiler to 350ppmv on a dry basis corrected to 8

### percent oxygen when firing

### black liquor for the complete 24-hourblock period. Install CEMS on Recovery Boiler No. 3 to monitor SOzemissions. As needed, repair concentrator sets, install a new caustic day tank or other scrubbant receiving, handling and injection system and a new lift station to connect power boiler scrubber blowdown to the waste water treatment system. REQUIREMENTS PERTAINING TOTHE ENTIRE FACILITY Facility Wide Emission Caps and Operating Limits None Applicable. Facility Wide Federal Rule Standards None Applicable. Facility Wide SIPRule Standards None Applicable. Facility Wide StandardsNot Covered by a 

### Federal or SIPRule and Not Instituted as an Emission Cap or OperatingLimit None Applicable

Page 1of 11Title V Permit Amendment Georgia-Pacific Corporation- Cedar Svrinw O~eration PermitNo.: 2631-099-0001 -V-02-6 PART 3.0 REQUIREMENTS FOR EMISSION UNITS 

### Note: Except where an applicable requirement specifically states otherwise, the averaging times of any of the Emissions Limitations or Standards included in this permit are tied to orbased on the run time(s) specified for the applicable reference test method(s) or procedures required for demonstrating compliance. 3.1.1 

### Additional Emission 

### Units

U500

U501

R402

Genera Power BoilerNo. 1

Power BoilerNo. 2

Recovery Boiler No. 3 Specific Lirnitatio nqu~rerncnts~~~ranuar~~s ---- - . . . ----- . . 40 CFR 61 SubpartE 40 CFR 63 SubpartDDDDD 40 CFR 64 391 -3-1-.02(2)@) 391-3-1-.02(2)(d) 391-3-1-.02(2)(g) 40 CFR Part 51 Append~x Y

40 CFR 61 SubpartE 40 CFR 63 ~ub~art DDDDD 40 CFR 64 391-3-1-.02(2)(b) 391-3-1-.02(2)(d) 391-3-1-.02(2)(g) 40 CFR Part 51 Appendix Y

40 CFR 63 SubpartMM 40 CFR 64 391 -3-1-.02(2)(b) 391-3-1-.02(2)(e) 391-3-1-.02(2)(g) 391-3-1-.02(2)(gg)l(i) 40 CFR Part 51 Appendix Y &miitions - .--- - - - 3.2 8 through 3.2.12, 3.2.19,3.3.4 through 3.3.6,3.3.9, 3.3.16,3.4.13 through 3.4.16,3.3.19, 3.5.1,4.2.1,4.2.2, 4.2.4 through 4.2.6,4.2.12, 4.2.26,5.2.1 through 5.2.3, 5.2.8,5.2.19,5.2.21, 6.1.7,6.2.14 through 6.2.16, 6.2.18 through 6.2.21, and 6.2.23 through 6.2.25,6.2.47 and 6.2.48* 3.2.8 through 3.2.12, 3.2.19,3.3.4 through 3.3.6, 3.3.9,3.3.16,3.4.13 through 3.4.16.3.3.19, 3.5.1,4.2.1,4.2.2, 4.2.4 through 4.2.6,4.2.12, 4.2.26, 5.2.1 through 5.2.3,5.2.8, 5.2.19,5.2.21, 6.1.7,6.2.14 through 6.2.16,6.2.18 through 6.2.21, and 6.2.23 through 6.2.25,6.2.47 and 6.2.48, 3.2.5,3.2.6, 3.2.12,3.3.6, 3.3.8, 3.3.14,3.4.7 through 3.4.9,4.2.1,4.2.8 through 4.2.11,4.2.27, 5.2.1 through 5.2.3, 5.2.5, 5.2.13,5.2.19,5.2.23, 5.2.28, 5.2.29,6.1.7, 6.2.3, 6.2.4, 6.2.7 through 6.2.13, 6.2.23 through Air 1 

### -- IDNo. --- C500 S500

C50l S501

C402

6.2.25,6.2.39 and 7.14.1* applicable requirements contained in this permit may also apply to emission units listed above. Drscription

- Multicyclone Venturi Scmbberwith Caustic solutionasscrubbing media or limestone injection system

Multicyclone Ventun Scrubberwith Caustic solutionas scrubbing media or limestone injection system

Dry Bottom Electrostatic Precipitator

Page 2 of 11Title 

### V Permit Amendment Georgia-PacificCorporation- Cedar Springs Operation Permit No.: 2631 -099-0001-V-02-6
3.2 Equipment Emission Caps and Operating

### Limits [Modified Permit Condition] 

### Recovery Boiler No. 3 3.2.6 Upon completion of the BART Exemption Project, the Permittee shall not discharge or cause the discharge into the atmosphere from Recovery Boiler No. 3 

### (Source Code R402) any gases which contain: c. When firingblack liquor solids, Sulfur dioxide emissions in excess of 350ppm on a dry basis corrected to 8

### percent oxygen as ablock 24-hour period beginning each calendar day at 12 midnight or other appropriate starting times asmay be specified or approved by the Division. [40 CFR Part 5 1Appendix Y-BART] [Modified Permit Condition] 

### 3.2.8 The Permittee shall bum no more than 

### 10,000pounds per hour and 120tons per day of tire derived fuel (TDF) in Power Boilers No. 1 and No. 2 cornbined (Source Codes U500 and U501). The permittee is also allowed to bum peanut hull or whole peanuts in the Power Boilers 1 and 2. [Avoidance of40 CFR 52.211

[New Permit Condition] 

### Power Boilers No. 1 and No. 2 3.2.19 Upon completion of the BART Exemption Project, the Permittee shall abide by the following emission limits: [40 CFR 51.308(e)]

a. The Permittee shall not discharge or cause the discharge into the atmosphere from Power Boiler No. I and Power Boiler No. 2 any gases that contain sulfur dioxide (SO2) exceeding 135 

### pound per hour each averaged over a block 24-hour period beginning at midnight or other appropriate starting times as may be specified or approved by the Division.

Page 3 of 11Title V Permit Amendment Georgia-Pacific Corporation- Cedar SpringsOperation Permit No.: 2631-099-0001 -V-02-6 PART 4.0 REQUIREMENTS 

### FOR TESTING 4.2 Specific Testing Requirements [New Permit Conditions] 4.2.26 Within 90 days of the completion of the BART Exemption Project, the Permittee shall perform an initial compliance test on Power Boilers No. 1 and 2 to determine compliance with the limits specified in Condition 3.2.19 to meet the limits specified in Condition 3.2.19. The 

### RATA test and the performance test shall be performed simultaneously. The compliance with the emission limits in Condition 3.2.19 will be demonstrated using continuous 24 hour of CEMS data, the first hour starting with the first hour of RATA testing. [Georgia Rule 391-3-1-.02(6)(b)1] 4.2.27 Within 90 days of the completion of the BART Exemption Project, the Permittee shall perform an initial compliance test on Recovery Boiler No. 3 (Source Code R402) to determine compliance with the limits specified in Condition 3.2.6. The RATA test and the performance test shall be performed simultaneously. The compliance with the emission limits in Condition 3.2.6 will be demonstrated using continuous 24 hour of 

### CEMS data, the first hour starting with the first hour of RATA testing. [Georgia Rule 391-3-1-.O2(6)(b)l

### J

Page 4 of l 1Title 

### V Permit Amendment Georgia-Pacific Corporation- Cedar Springs Operation Permit No.: 2631-099-0001 -V-02-6 PART 5.0 REQUIREMENTS FOR MONITORING (Related to Data Collection) 5.2 Specific Monitoring Requirements [Modified Permit Conditionj 

### 5.2.1 The Permittee shall install, calibrate, maintain, and operate a system to continuously monitor and record the indicated pollutants on the following equipment. Each system shall meet the applicable performance specification(s)ofthe Division's monitoring requirements. [391-3-1-.02(6)(b)l and 40 CFR 70.6(a)(3)(i)]

c. Opacity, TRS, sulfur dioxide and oxygen from Recovery Boiler No. 3 (Source Code R402). The requirement for the installation of a continuous monitor for sulfur dioxide will be effective on the date ofthe completion ofthe BART ExemptionProject [40 CFR Part 51,40CFR 63 Subpart MM; 

### 40 CFR 63.864(d); Georgia Rules 391-3-I-. 02(2)(b) and 391 

### -3-2-.02(2)(gg)] [Modified Permit Condition] 

### 5.2.2 The Permittee shall install, calibrate, maintain, and operate a system to continuously monitor and record the indicated parameters on the following equipment, Where such performance specification(s) exist, each system shall meet the applicable performance specification(s) ofthe Division's monitoring requirements. [GeorgiaRule 391-3-1-.O2(6)(b)l and 40 CFR 70.6(a)(3)(i)] d. Pressure drop and scrubbant flow rate from the scrubbers on Power Boiler No. 1 and No. 2 (Source Codes U500 and U5O 1). [Modified Permit Condition] 

### 5.2.19 The following pollutant specific emission units (PSEUs) are subject to the Compliance Assurance Monitoring (CAM) Rule in 40 CFR 64.



### .. I*J 

### -- -2. P "-' " . -

,



### .>r?- - ' yy.7t'$%%T*<- -- . Y~,;. :-; ,ti. 

### . ,J :-=--y -> '5.> 'E-ki&;6$ 

### &.-

. .,

### . . ,# **4,y

. ,., - , . -7 . , 5.. .. ,, ,.. . ----

. -
. - .-\ ...- ,- , .. - 

## - Lime Handling System (Group Code LEG2) Power Boiler Nos. 1 and 2 (Source CodesUS00 and U501) 

### \ PM, SO2 Lime Kiln Nos. 1 and 2 (Source Codes L600 and L601) 1 PM 

# 1
I Incinerator / Scrubber System (Source Code R425) 

### I PM, SO2 

## I

Recovery Boiler Nos. 1 and 2 (Source Codes R400 and R401) Recovery Boiler No. 3 (Source Codes R402) Smelt Dissolving Tank Nos. 1,2,and 3 (Source Codes R404, R405, and R406)



### Permit conditions in this permit for the PSEU(s) listed above with regulatory citation 40 CFR 70.6(a)(3)(i) are included for the purpose of complying with 40 CFR 64. 

### In addition, the Permittee shall meet the requirements, as applicable, of40 CFR 64.7, 64.8, and 64.9. [40 CFR 641 PM PM PM 1

Page 5 of 11Title 

### V Permit Amendment Georgia-Pacific Corporation- Cedar Springs Operation Permit No.: 2631

### -099-0001-V-02-6 lModified Permit Condition] 5.2.21 

### The Permittee shall comply with the performance criteria listed in the table below for the particulate matter and sulfur dioxide emissions from Power Boiler Nos. 

### I and 2 (Source Codes U500 and U501): [40

### CFR 64.6(c)(l)(iii)]

Yrformance Criteria 644q311 - IndicatorNo. 3 Sc~bbant Flow RmJc 

# 1

A. Data The flow rate is Representativeness measured using standard [64.3@)(1

### )I instrumentationprovided 

# 1 1

for this purpose.

B. Verification of Operational Status (newlmodified monitoring equipment only)[64.3(b)(2)] iiilicaforNo, 2 'r-

. - 'rwurc DropAcross ;cn~ hbcr

C. QNQCPractices and Criteria [64.3(b)(3)] The differential pressure across the scrubber will be measured using standard instrumentation

Annual Calibration. Annual Calibration

E. Data Collection Recorded by the mill Procedures data collection system. D. Monitoring Frequency [64.3(b)(4)] Recorded by the mill data collection system. Continuous.

[New Permit Condition] Continuous.

F. Averaging Period [64.3(b)(4)]

5.2.29 

### For the sulfur dioxide CEMS installed on Recovery Boiler No.3 (Source Code R402) the Permittee shall perform annual RATA tests, quarterly accuracy determinations, and daily CEMS drift checks in accordance with the followingprocedures and requirements: [GeorgiaRule 391-3-1-.02(6)(b) (vi)]

a. A Relative Accuracy Test Audit (RATA) shall be conducted on the CEMS at least once every four successive operating quarters. The procedures of Appendix F of 40 

### CFR Part 60 shall be used to conduct the RATA. The results of a RATA shall be submitted to the Division within 60days of completion ofthe RATA. 3-hour average.



### b. A cylinder gas audit shall be conducted at least once every quarter in accordance with Appendix F of40 CFR 60. 3-hour average.



### c. CEMS drift checks shall be conducted daily in accordance with 40 CFR 60.13(d). Page 6 of 11Title V Permit Amendment Georgia-Pacific Corporation- Cedar Springs Operation Pennit No.: 263 1-099-0001-V-02-6 PART 6.0 OTHER RECORD KEEPING AND REPORTING REQUIREMENTS 

### 6.1 General Record Keeping and Reporting Requirements [Modified Permit Condition] 6.1.7 For the purpose of reporting excess emissions, exceedances or excursions in the report required in Condition 6.1.4, the following excess emissions, exceedances, and excursions shallbe reported: [391-3-1 -.O2(6)(b)l and 40 CFR 70.6(a)(3)(i)]

a. Excess emissions: (means for the purpose ofthis Condition and Condition 6.1.4, any condition that is detectedby monitoring or record keeping which is specifically defined, or stated to be, excess emissions by an applicable requirement) Recovery Boilers No. 3

xv. Upon completion of the 

### BART Exemption Project, the Permittee shall abide by the following: For Recovery Boiler No. 3 (Source Codes R402), any block 24-hour period beginning at midnight during which the SOz emissions, expressed as the arithmetic average of 24 contiguous 1-hour periods, measured and recorded in accordance with 5.2.1.c is in excess of 350ppm on a drybasis corrected to 8 percent oxygen when firing black liquor only for the complete 24-hour period. [40 CFR 51.308(e)]

Power Boilers No. 1 and 2 xvi. Upon completion of the BART Exemption Project, the Permittee shall abide by the following:

For Power Boiler No. 1 and 2 (Source Codes U500 and U501), any 24-hour period during which the 

### SO2concentration, expressed as the arithmetic average of 24 contiguous 1-hour periods, measured and recorded in accordance with 5.2.1.b and calculated in accordance with Conditions 6.2.18 exceed 135Ibs per hour. [40 CFR 51.308(e)]

Page 7 of 11Title V Permit Amendment Georgia-Pacific Corporation- Cedar Springs Operation Permit No.: 263 1-099-0001-V-02-6
6.2 Specific Record Keeping and Reporting Requirements Modified Permit Condition 

### Power BoilersNo. 1and No. 2 6.2.18 For each calendar day and while Power Boiler No. 1 (Source Code U500) is subject to Condition 3.5.1, the Permittee shall calculate the tons of sulfuric acid mist (SAM), particulate matter (PM), sulfur dioxide (SOz), nitrogen oxides (NOx), and carbon monoxide (CO) emitted from the boiler. All hourly averaged data necessary to perform these calculations shall be maintained. The calculations for each calendar day must be complete with 72hours following the end ofthat calendar day. The equations to beused for each calculation follow. [Avoidance of40 

### CFR 52.2 11



### a. SAMEmissions:

IbhrSAM ~M,'o"= T[(SAM Emission Factor,---- 

# XSO, Emission Rate, ,- day i=, IbhrSO, 

### b. PM Emissions:

MMBtu PM,~ = $[(-mi Heat ,"put,,- 

# XPM Emission hr



### c. NOx Emissions:

d. COEmissions:

24 D5CF 20.9% COConci,lb Ib 7.48 gal MMBtu l tonCO CQ1.day =c[(F - Factori.&)( - 02% 

# 1 , 06,b XGas Den%-~T~Hcat bi,TX----)] i=l gal 2,000Ib



### e. SO2Emissions:

24 

### so2.~= z[(F - Factor,,- 20.9% SO2Conc,, lb

# 1 lb, 17.:F11 DScF

# X X 10~16 Gas Dens,- - MMBtu l ton SO2 Heat Ini,--x---)] day MMBtu 20.9%-02% hr 2,0001b

20.9% 1hour average SOZ Conc,, lb (~~rtlow DSCFh, -- 20 9%-01% 

# i 

# X I06/b 

### For the purposes of this condition, the variable i 

### represents hour i 

### of the calendar day and any emission factors, airflow or F-factors used in the above calculations will be established upon the most recent Division-approved performance testing. Page 8 of 1 1

### Title V Permit Amendment Georgia-Pacific Corporation- Cedar SpringsOperation Permit No.: 2631-099-0001-V-02-6 

### For the purposes of this condition, the variable i represents hour i 

### of the calendar day and any emission factors, airflow orF-factors used in the above calculations will be established upon the most recent Division-approved performancetesting.
[New Permit Conditions1 6.2.47 The Permittee shall submit the actual date of the completion of the BART Exemption Project. This submittal shall include certification that a final inspection has shown that the BART Exemption Project was 

### completed in accordance with Application No. 18385. This notification shall be submitted within 15 days following the completion of the BART 

### Exemption Project. [Georgia Rule 391-3-1-.OZ(6)(b)l and 

### 40 CFR 70.6(a)(3)(i)] 6.2.48 At the end of each calendar month and while Power Boiler No. 1 and Power Boiler No. 2 

### (Source Code U500 and 501) is subject to Condition 3.3.19, the Permittee shall calculate and record both monthly emission totaIs and twelve-month rolling emission totals for sulfur dioxide (SOz)using the daily results of Condition 6.2.18. When a monthly emission total exceeds 49.27 tons for SO2for any of the Power Boilers, the Permittee shall submit a statement indicating how the Permittee intends to meet the applicable limit(s) specified in Condition 3.3.19; this statement shall be submitted by the 30~ day ofthe following calendar month. Records of all monthly and twelve-month rolling emission totals, records of demonstration calculations, records of any factors used in the calculation of criteria pollutant emissions, and other supporting documentation shall be maintained. These records shall be kept 

### available for inspection by or submittal to the Division for a period of five years following the date ofrecord. [Avoidanceof 40 CFR 52.21,40 

### CFR 51.308(e)]

Page 9 of 11

### Title V Permit Amendment Georgia-Pacific Corporation- Cedar Springs Operation PermitNo.: 2631 -099-0001-V-02-6 

### PART 7.0 

### OTHER SPECIFICREQUIREMENTS 7.1 Operational Flexibility Associated with this Amendment 7.2 

### Off-Permit ChangesAssociated with this Amendment 7.3 

### Alternative Requirements Associated with this Amendment [White Paper #2] Not Applicable 7.4 

### Insignificant Activities Associated with this Amendment (see Attachment B for the list of Insignificant Activities in existence at the facility at the time of permit issuance) 

### 7.5 Temporary SourcesAssociated with this Amendment [391-3-1 -.03(l O)(d)5 and 40 CFR 70.6(e)] Not Applicable 7.6 

### Short-term Activities Associated with this Amendment (see Form D5 "Short Term Activities" ofthePermit application and White Paper 

### #1) Not Applicable. 7.7 

### Compliance ScheduleIProgressReports Associated with this Amendment [39l-3-l-.O3(l O)(d)3 and 40 CFR 70.6(~)(4)] None applicable. 7.8 

### Emissions TradingAssociated with this Amendment [391-3-1-.03(l O)(d)l

### (ii) and 40 

### CFR 70.6(a)(l 0)] Not Applicable 7.9 

### Acid Rain Requirements Associated with this Amendment Not Applicable. 

### 7.12 Revocation of Existing Permits and Amendments The following Air Quality Permits and Amendments are subsumed by this permit and are hereby revoked:

Page 10of 11

AirQaalikfe-mit hnbe@s) 263 1-099-0001 -V-02-5 -.\- _Dates&f OnglnalJe@ Iaunnie~r ~ni&in'dhe~t - Feb 24,2009Title V Permit Amendment Georgia-Pacific Corporation- Cedar SpringsOperation PermitNo.: 2631-099-0001 -V-02-6 7.13 Pollution Prevention Associated witb this Amendment 

### Not Applicable 7.14 Specific Conditions Associated with this Amendment [NewPermit Condition] 7.14.1 

### The 

### BART Exemption Project including changes identified in Condition 1.3 

### to comply with 

### BART exemption shall be completed by July 30,201 1.

Page 11of l l

# Georgia Department of Natural Resources Environmental Protection Division Air Protection Branch 4244 International Parkway Suite 120 Atlanta Georgia 30354 4041363-7000 Fax: 4041363-7100 Chris Clark, Commissioner

F.Allen Barnes, Director
December 11,2009

MEMORANDUM To: F. Allen Barnes, Director Environmental Protection Division From: James Capp, Chief Air Protection Branch Subject: Responsesto Comments Received Regarding Georgia's Proposed State lmplementation Plan for Regional Haze
U.S. EPA's Regional Haze Rule (40 CFR 51.308) requires states to demonstrate reasonable progress toward meeting the goal of a return to natural visibility conditions in the nation's Class I (wilderness) areas by 2064. Three federal Class I areas are located within the State of Georgia: the Cohutta Wilderness Area, the Okefenokee Wilderness Area, and the Wolf Island Wilderness Area. In compliance with the requirements of 40 CFR 51.308, the Environmental Protection Division (EPD) of the Georgia Department of Natural Resources is submitting to EPA Georgia's State lmplementation Plan (SIP) revision which demonstrates Regional Haze Reasonable Progress in our Class I areas through 2018. The Regional Haze Rule requires states to take comment on their proposed regional haze plans from both federal land managers (FLMs) and from the public. The FLMs have direct responsibility for the Class I areas. EPD's actions with respect to the comment process are summarized below. EPD submitted the draft plan on December 18, 2008, to FLMs from the following agencies: U.S. Forest Service, National Park Service, and U.S. Fish and Wildlife Service. The plan was received by the above agencies on December 22, 2008. Comments were received from all three of the agencies. EPD's responses to the comments are attached and have also been included in the Regional Haze Plan as Appendix 0. On July 26, 2009, EPD issued a public notice in the Atlanta Journal-Constitution requesting comments on proposed amendments to Georgia's State lmplementation Plan. The amendments were described in the notice as follows: "The proposed State lmplementation Plan revision incorporates Georgia's Regional Haze State lmplementation Plan for improvement of visibility in Georgia's three federally designated wilderness areas
. ..". No oral comments were received during the public hearing held on August 27, 2009. Written comments were received from EPA, the U.S. Fish and Wildlife Service, and the National Park Service during the public comment period. Comments received and EPD's responses are attached. JC:JK:klcState of Georgia Responsesto Comments Received During the Public Comment Period July 26 through August 27,2009 Proposed State lmplementation Plan Revision Incorporating the Regional Haze State lmplementation Plan On July 26, 2009, EPD issued a public notice requesting comments on the proposed State lmplementation Plan revision incorporating the Regional Haze State lmplementation Plan. No oral comments were received during the public hearing on August 27, 2009. Written comments were received during the public comment period. Comments received are summarized in this memo. Issues raised by the commenters, followed by EPD's responses to the commenters' assertions, are presented below. Public Hearing No oral commentswere received during the public hearing. Written Comments Commentswere received from EPA, Region 4 and from the U.S. Fish and Wildlife Service and National Park Service of the Departmentof Interior (DOI). The DO1 comments were received after the comment deadline, but are addressed below. The DO1 and other Federal land Manager Comments were to be addressed by a formal consultation process as defined in the Regional Haze Rule and are documented inAppendix 0. EPA comments are presented verbatim below with respective responses. The response to EPA Key Comment 3 also respondsto a portion of the DO1 comment.
I. Key Comments: The following comments must be addressed in the SIP to meet the requirementsof the regional haze regulations and/or SIP completeness and approvability criteria. Key Comment I:Enforceable Emission Limits in the 

### SIP. "Appendix 

### M contains permit conditions for emission units at four facilities to satisfy the State's determination of Best Available Retrofit Technology (BART) andlor reasonable progress: Interstate Paper-Riceboro (BART), GA Pacific Brunswick Cellulose (reasonable progress), International Paper-Savannah (reasonable progress), GA Pacific Cedar Springs (reasonable progress and BART exemption limit). Enforceable emission limits and compliance schedules are required to be in the SIP per 40 CFR Part 51.308(d)(3) for reasonable progress, and 40 CFR Part 51.308(e)for BART. Emission control measures adopted into the State lmplementation Plan (SIP) as federally enforceable must beenforceable by the State. Inthis document, the proposed emission limits and compliance schedules do not appear to be in a form that the State can enforce. We understand that the State is in the process of incorporating these emissions limits and supporting conditions into permitsfor the affected facilities, and that the permit processes will likely be completed after the final SIP is submitted. Please submit the relevant portions of the final permits as a SIP revision, along with the dates the provisions are officially adopted by and effective in the State, to include with the State's Regional Haze SIP. Providingthe emission limits in a state-enforceable mechanism will enable the Agency to take final action on Georgia's SIP, making the Regional Haze SIP revisions federally enforceable. Also, it would be helpful if the State could indicate its estimated schedule for these source-specific SIP submissions. Ifthe State has the authority and intends to rely on enforcement of the proposed emission limits and compliance schedules as presented in the SIP, please submit evidence that the State hasthe necessary legal authority under State law to adopt and implementthe State's Regional Haze SIP, includingthe emission limits for BART and reasonable progress listed in narrative form in Appendix M." 

### EPD Response: EPD will rely on the enforcement of the final permits, as authorized by the Georgia Air Quality Act, Section 12-9. The relevant portions of all final permits will be included with the submission of this SIP and identified in the Administrative Material Checklist. As any remaining permits are finalized, this SIP will be amended accordingly. Outstanding permits are expected to be final within six months of submittal of this SIP unless extenuating circumstances dictate otherwise. Key Comment2: Georaia Pacific Cedar Sprinas 

### BART Exemption Determination. "Georgia Pacific Cedar Springs was exempted from BART becausethe facility accepted SO2 emissions limits on Power Boilers 

### 1 and 2 (135 Iblhr each) and on Recovery Boiler 3 (350 ppm). These limits result in a 0.499 deciview impact at St. Marks and a 0.306 deciview impact at Okefenokee National Wildlife Refuges (NWR). The BART exemption limits will result in over 70 percent control of the two power boilers. The permit has been issued with Federally-enforceable limits and a Federally-enforceable condition that requires the facility to monitor their emissions and to notify the State if they exceed the BART exemption limit. The compliance date for these exemption limits is July 30, 2011. We also note that a 4-factor analysis was performed for reasonable progress for this facility. It concluded that adding caustic to the existing venturi scrubber or in-duct sorbent injection was reasonably cost effective and, depending on the level of caustic injected, would result in 37-79 percent reduction in SO2 from the power boilers. No controls were identified as being reasonably available for the recovery boiler. On this basis, GA EPD concluded that the BART exemption limits, which will achieve greater than 70 percent SO2 reduction,were sufficient for reasonable progressfor this facility.EPA is concerned with the compliance date of July 30, 2011. Although we have not directly addressed this issue in a rulemaking context, generally we would expect a source seeking exemption from BART to have reduced its impacts to belowthe significance level, or for the State to include a BART determination for the currently BART-eligible source in its Regional Haze SIP submittedto EPA as required by 51.308(e). We recognize that if this were a BART determination, the date selected would likely be considered acceptable and as expeditiously as practicable. However a BART exemption avoids the needfor an actual determination and is subject to different considerations. Please provide your reasoningfor concluding that extending the date for the BART exemption to July 30, 2011, was appropriate in this instance and howthe conclusions of the BART analysis, if one had been done, might differ from the conclusions of the reasonable progress analysis." 

### EPD Response: EPD understands EPA's concern with the compliance date. Georgia-Pacific, in a communicationto EPD dated September 12, 2007, estimated the time intervals that would be needed to design, install (including demolition), and start up the different control options that were presented as technically feasible in the 4-factor analysis submitted by the Company. As noted in the SIP narrative and in the comment above, EPD determined that addition of caustic to the existing venturi scrubber or installation of in-duct sorbent injection were reasonable control options and would meet the requirements of both a BART exemption (less than 0.5 deciview impact) and reasonable progress. Georgia-Pacific estimated the time intervals to implement caustic addition and sorbent injection as being 18 and 36 months, respectively.

. To achieve the proposed BART exemption limits continuously, GP must install a new caustic storage and delivery system and evaluate re-configuring components of the existing scrubbers. Also, the Mill has no operating experience with the proposed high caustic usage rates and its impact on the Mill'swastewater treatment system. The captured sodium-sulfates will add as much as 15,000 tons of material to the existing scrubber blowdown system. Therefore, GP projected a startup date of 2011 to accommodate both construction activities and investigation of downstream effects on the existing scrubber blowdown management. Sorbent injection is a technique that requires significant physical modification to the boilers themselves. Inaddition to the boiler engineering requirements, the Mill would require additional time to investigate proper management of the high increase in boiler ash (as captured calcium-sulfates). As the sorbent injection equipment is more expensive, GP believed that the selection of this option could come after the caustic addition option was completely evaluated. EPD issued Permit No. 2631-099-0001-V-02-6, which requires the emissions reductions needed for regional haze, with an effective date of July 23, 2009, and a regional hazecompliance date of July 30, 2011. Adding 18 months and 36 monthsto the effective date of the permit would result in the following estimated completion dates of controls:

Based on these estimates,the current permitted compliance date of July 201 1 seems very reasonable. Caustic addition Sorbent injection

EPD does not envision that the SO2 emission reductions would have been different had Georgia-Pacific been required to complete a BART determination. A BART determination uses a 5-factor process, with the only difference from the 4-factor analysis being the factor of visibility improvement expected. Furthermore, the compliance date under a BART determination would have been 201 3 or 2014 (five years from the date of the determination). This would mean controls coming on line two or three years later than what is required by the existing permit. January 201 1 July 201 2

Under a BART determination, the pollutants S02, NOx, and particulate matter 

### (PM)would have been addressed. As discussed in Section 7.4 of the SIP, however, emission sensitivity modeling performed by Georgia Tech demonstrated that the visibility benefits at Georgia's Class 

### I areas of reducing NOx and PM would be very small compared to the benefits of reducing S02. Also under a BART determination, three additional emissions units (subject-to-BART units) would have been addressed: Smelt Dissolving Tank No. 3 (R406), Lime Kiln No. 1 (L600), and Lime Kiln No. 2 (L601). However,the SO2 emissions rates of these units are significantly less than the rates of units addressed by the 4-factor analysis: Power Boilers 1 and 2 and Recovery Boiler No. 3. The sum of the 24-hour maximum SO2 emissions rates of the three former units is less than 4% of the sum of the emissions rates of all six emissions units (three 4-factor units plus three additional units under BART). It is therefore highly unlikely that a BART determination would have resulted in controls on R406, L600, or L601. 

### Key Comment 3: 

### Appendix H.8

### - BART Analysis for Interstate Paper. "The cost of NOx controls presentedfor the power boiler and lime kiln are well within the range of what has been found to be reasonable for many other sources. If your BART determination is based in part on the lack of further effectiveness of NOx controls in reducing Regional Haze in the impacted Federal Class I areas, Region 4 recommendsyou prepare an air quality analysis assessingthe change in deciviews expected from further NOx control to better document your findings." Additionally, the DO1 commented on the cost effectiveness of NOx controls and the date provided. While these concernswere addressed during the formal Federal Land Manager consultation required by the rule inAppendix 

### 0,the response to EPA1s comment also effectively addressesthe DO1 comment.

### EPD Response: EPD agrees with DO1 and EPA's comment and the statements pertaining to the cost of NOx controls have been revised. NOx controls are not considered further for BART analysis because of their relatively small benefit to visibility at Georgia's Class I areas. An analysis of the visibility benefits of SO2 control and NOx control has been added as new Section 

### 5 of Appendix H.8.
II. Suggested Clarifications (SCs). The following comments are suggested clarifications that would be helpfulto more clearly portraythe information presented. SIP Narrative

## - Main Report: 

### SC Narr Comment 

### I: Page ii of Executive Summary and Page 

### 12

### - BestWorst Visibility Davs. "Please notate on page ii of the Executive Summary and page 12 of the SIP Narrative the location of a listfor the 20 percent best and worst days used in the regional haze technical analyses for the Georgia Class I areas." 

### EPD Response: Tables of the 20% best and worst visibility days have been added to the SIP as new Appendix 

### B.1. The new appendix is referenced from Section 2.2 of the narrative.


### SC Narr Comment

### 2: Page 

### 13

## - Table

### 2.3.I. Natural Background and Baseline Conditions for Georgia Class 

### 1Areas: "The second column under the 'Natural Background Conditions' header is labeled as 'Average for 20 percent Best Days (deciviews).' This should be changed to 'Average for 20 percentWorst Days (deciviews)'." 

### EPD Response: The header was corrected


### SC Narr Comment3: 

### Paqe 

### 81

### - EPA Reasonable Progress Guidance. "For clarity, we suggest that the reference to 'EPA Guidance' on Page 81 be specified with the page from the Guidance describing the concept of allowing a BART control analysis to satisfy a reasonable progress control analysis (i.e., pp. 4-2 to 4-3)."

### EPD Response: The change has been made as suggested.


### SC Narr Comment 4: Page 87

### - Georqia Power, Plant Kraft, Steam Generators 

### I, 2, 

### and 

### 3. "Thefollowing statement appears on Page 87 of the SIP Narrative: 'Coal washing was relatively cost effective ($1839 to $1847/ton and $32.5 to $32.7/Mm-1) but the control efficiency is only 6%. Based on these factors, no additional controls will be required for any of the Plant Kraf? Units.' It is suggested that the additional discussion of the negative nonair environmental impacts of the coal washing option, discussed on Page 88 of Appendix H, be added to the summary in the SIP narrative to provide further support for the conclusion that coal washing is not reasonable." 

### EPD Response: The narrativewas revised as suggested.


### SC Narr Comment 5: Paaes 89, 90 

### - lnternational Paper, Savannah, Power Boiler 

### 13. "The discussion on pages 89-90 of the SIP Narrative indicates that International Paper requested a 2016 compliance date for meeting the revised SO2 emission limit of 6578 tonslyr and that GA EPD has agreed that this is appropriate. The discussion of the rationale supporting the 2016 compliance date is limited in the SIP Narrative, but more detail is provided on Page 94 of Appendix 

### H. It is suggested that the discussion in Appendix H regarding EPA's timeline for revising the vacated and remanded Boiler MACT rule be included in the SIP Narrative as well to support such a delayed compliance date." 

### EPD Response: The narrativewas revised as suggested.


### SC Narr Comment 6: 

### Page 91 

### - Temple-InlandRome Linerboard, No. 4 Power Boiler. "On page 91, the SIP indicates that "'None of the control options considered had a cost effectiveness that was determined reasonableat this time.' However,the cost effectiveness information presented on pages 97-98 of Appendix 

### H indicates that the costs are within the range of costs which were deemed to be reasonable for other sources being controlled for reasonable progress (e.g., GA Pacific Brunswick Cellulose and GA Pacific Cedar Springs). The discussion starting on page 95 of Appendix 

### H appears to rely on the air quality impacts of the reasonable progress determination. Additional rationale, clarifying the reliance onthe impacts on visibility, should be provided inthe SIP Narrative."

### EPD Response: The text on Page 91 has been revised to say the following: "The fact that the affected Class I areas impacted by this unit are predictedto meet the Uniform Rate of Progress in 2018 with controls that are already on the bookswas a key factor in determining what was considered 'reasonable' for reasonable progress requirements for this source. This determination may be revisited at the mid-course review or when determining future Regional Haze reasonable progress goals (i.e., future Regional Haze SIPS.)"


### SC Narr Comment 7: 

### Paqe 97. "The State separately submitted emissions limits in issued permit amendments that facilities have taken to be exempt from performing 4-factor analyses. The permit conditions inTable 7.6.4-2 for Rayonier Performance Fibers do not appear to include the compliance date of January 1, 2012, for exemption from reasonable progress analysis." 

### EPD Response: The table shows a compliance date of January 1, 2012. The table is in error and has been revisedto reflect the requirements of the permit conditions, which are described below. The emissions limits for exemption from 4-factor analysis were added to Rayonier's permit with the permit amendment issued in June 2008. The permit contains conditions that will limit SO2 emissions from four emissions units: Power Boiler No. 2, Power Boiler No. 3, No. 5 Recovery Furnace, and No. 6 Recovery Furnace. The limits on the power boilers are based on Regional Haze requirements and will result in combined reductions of SO2 emissions from the two units of over 1600 tons compared to 2018 projections without limits. These limits, with record-keeping requirements, became effective upon issuance of the permit revision (June 2008). The limits on the recovery furnaces are based on PSD avoidance and on Regional Haze and will result in combined reductions of SO2 emissions from the two units of just under 200 tons compared to 201 8 projectionswithout limits. The limit on RFOI becomes effective upon the completion of the Plant's Phase 1 projects, which include the addition of SO2 control (staged air combustion). The limit on RF04 becomes effective uponthe completion of the Plant's Phase 2 projects,which include the addition of SO2 control (staged air combustion). The permitting of Phases 1 and 2 allows for increased production and burning of black liquor solids, but only after the emissions controls are installed. At the time of this SIP submittal, Phase 1 (partially complete including the SO2 control) and Phase 2 (not started) were suspended due to depressed market conditions in 2009.

### SC Narr Comment 8: 

### Paqe 109

### - Smoke Manaaement Plan (SMP): "Consider inserting into the Section 7.6 discussion of Georgia's SMP how the plan can be viewed by interested parties." 

### EPD Response: The pertinent section is Section 7.8 rather than 7.6. The text has been revised as suggested.

Appendices: 

### SCAppendix H Comment ?.a: Tables 7-1 and 7-2

### - Best Available Retrofit Technoloqv (BART). "Table 7-1 on Page 103 in Appendix 

### H does not provide distances to the applicable Class 

### I areas for Georgia Power 

### - Plant Bowen, Prayon and Georgia Pacific-Cedar Springs. Table 7-2 on page 109 in Appendix H states that a PCS Phosphate facility is a major Georgia ammonia BART source that is 31 kilometers (km) from an unspecified Class I area. We assume that this source is the PCS Phosphate Savannah Ammonia Terminal in Savannah, Georgia. We also assume that it must be close to the Wolf Island Class I area. Please clarify that the facility does not have other BART pollutants that make it BARTeligible.'' 

### EPD Response: Table 7-1 does not have the distances listed as a part of the BART exemption modeling processfor Georgia Power - Plant Bowen, and Prayon Inc. because exemption modeling was not performed on these sources. The table has been changed to indicate that. However, for Georgia Pacific 

### - Cedar Springs, the distance was left off as an oversight. The information has now been added to the table as requested. PCS Phosphate is PCS Phosphate - Savannah Ammonia Terminal in Savannah. The facility is a minor source for all pollutants, and therefore, not BART eligible. However, the facility was taken into consideration in the ammonia evaluation. Changes have been made to better clarify this information. 

### SCAppendix 

### H Comment 1.b: Table 5-7,page 57

### - Reasonable Proqress: Mohawk Industries."Table 5-7 on page 57 of Appendix 

### H lists Mohawk lndustries as a facility that was dropped from further analysis because the facility updated their 2018 emission information, lowering sulfate visibility impact to less than 0.5 percent. This is similar to Miller Brewing, Mount Vernon Mills, and Savannah Sugar, which are shown in Tables 7.6.2-1 and 7.6.2-2 on pages 80 and 81 of the narrative. Previously this facility was classified as having shut down. Please clarify the status of this facility and update the appropriate tables and text." EPD Response: Mohawk lndustries was incorrectly listed as closed inthe pre-draft document. The facility only shut down its spinning operations. Because of this, the facility has had reduced capacity of its boilers. They have a total of five boilers, of which, only two to three operate at any given time. Steam is no longer needed in the shut down spinning operations, thus 2018 emissions were updated to take the shut down into account.
SCAppendix 

### H Comment 1.c: Paqe 56 

### - lnland Paperboard I Packaging. "Please address the permit status in the discussion on page 56 of Appendix 

### H for the permanent shutdown of the Temple Inland Rome (aka Inland Paperboard I Packaging, Inc.) facility's Unit F2. " EPD Response: According to correspondence from Temple Inland, the last day of operation of the Corrugated Container Plant (in Rome, Georgia) was November 11,2008. Georgia EPD revoked permit number 2653-1 15-088-V-02-0on April 15, 2009. The text of Appendix 

### H has been revised accordingly.
SCAppendix 

### H Comment 1.e: "Insert 'limit' into fourth column for point ID SAO2." EPD Response: The text has been revised as suggested. SC Appendix 

### J Comment 2.a: Pages J-7, J-8: "There are several sources that were identified through different methods as being eligible for a 4-factor reasonable progress control analysis that did not overlap betweenthe States of Georgia and Florida. Please list each of these emission units and state how the two States resolvedthe approach to addressing Florida emission units identified by Georgia'smethod (andthe Georgia emission units identified by Florida's method)."
EPD Response: The comment refers to emissions units within a state identified for 4-factor analysis by the neighboring state but not by the state in which it is located. It is to be expected that neighboring states may take different approaches to their Regional Haze programs. 40 CFR 51.308(i), which specifies state coordination requirements for Regional Haze, does not require differences in state Regional Haze programs to be resolved. Georgia EPD believes that it has met the state coordination requirements by virtue of its participation (with Florida) in VISTAS and its correspondence with Florida pertaining to coordination. The table below lists the sources and gives the current status of the Georgia sources. Facility Anchor Glass Anchor Glass Millenium Spec. Chemicals GA

### -Pacific Brunswick Inland Paperboard 

### & Packaging Interstate Paper 

### LLC
Mt. Vernon Mills
Mt. Vernon Mills Unit ID 3 source* sourcex* Current Status (GA sources only)

Unit was identified by GA and 4-factor analysis wasperformed. No additional costeffective controls were idenitied. Unit was identified by GA and 4-factor analysis wasperformed. No additional controls will be required at this time for the No. 4 Power Boiler. Unit was identified by GA as being subjectto-BART. EPD has made a BART determination which includes controls on this unit. Unit was identified by GA, but later removed from 4-factor requirement based on facilityprovided emissions estimates that were significantly lower than VISTAS estimates. Same as above.
* identified by Florida for 4-factor analysis but not by Georgia ** identified by Georgia for 4-factor analysis but not by Florida The three Florida sources identified by Georgia (but not by Florida) are smaller sources that were slightly over Georgia's threshold for sulfate impact on one or more Georgia Class I areas. EPD is not aware that Florida intends to control these sources during the firstRegional Haze planning period (ending in 

### 2018). No changes have been made to theproposed SIP in response to this comment.
SCAppendix 

### J Comment

### 2.b: Page 3. "Thetable of contents on Page 3 under '2. Consultation Letters' is very helpful. Note that there are several discrepancies in the last few entries listed from pages 50-55 in comparison to the referenced letters." EPD Response: The discrepancies have been corrected.
DO1 [Dept. of Interior]comment on BART 

### - First Paragraph. Appendix H of the Georgia Regional Haze State Implementation Plan - Draft (RH SIP) contains BART Exemption Modeling Reports for most Bart 

### - eligible sources. However, such reports are not includedfor the Owens Corning or Prayon, lnc. facilities. Please provide these reports in the record as evidence to confirm that neither of the above facilities impact visibility at any Class I area by 0.5 deciviews or greater. 

### EPD Response: The reports were included in the original prehearing SIP, but may have been difficult to locate due to the large amount of supporting documentation. Table 

### 8.I in Appendix 

### H summarizes the exemption modeling results for all affected facilities.