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 of submission. 

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) - "Clean Air lnterstate Rule 

SO2 Trading Program". This rule adopts 40 CFR Part 96, Subparts AAA 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 1-099-000 1-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. 

Enclosed is 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. 

Enclosed is 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 13 
Regional Haze State Implementation Plan for Georgia 

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. 

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 notice was 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 accordance with the information 

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

Enclosed is a copy of the Notice of Public Hearing and the Certificate of Public 

Hearing. 
Regional Haze State Implementation Plan for Georgia 

Technical Support for 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-attainment designation 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 7 6 and 7.7 of the 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. 

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 of models and data sets used by 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 Plan for Georgia 

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. 

Not applicable. 
Georgia Department of Natural Resources 

Environmental Protection Division Air Protection Branch 

4244 International Parkway Suite 120 Atlanta Georgia 30354 

4041363-7000 Fax: 4041363-71 00 

Chris Clark, Commissioner 

F. Allen Barnes, Director 

CERTIFICATE OF PUBLIC HEARING 

I do hereby certify that a public hearing was 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 

SAVANNAH MORNING 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 Southeastern Newspaper 

Corporation, a Georgia corporation, doing business in Chatham County, GA, 

under the trade name of Savannah Morning News, a daily newspaper 

published in said county; 

That he is authorized to make affidavits of publication 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. 

EUGENE J. ON# 

Notary PuMic, Chalham CowlPy, GA 

W Bymission Expires &wry B, Wte 
RECEIVED 

Geor$a FPD 

AUG 6 2009 

Hazardous S~tes 

Res~orise Program 

PUBLISHING COMPANY, INC. 

Georgia. Do~gherty comty 

Affidavit of Publication 

Personally, appehred before the undersigned. an officer, 

authorized to administer oaths. AUIIXZX Banaock, who being sworn, 

says that she, Ambcr H8ncook. the Classified Legal Clerk for The 

Albany Herald Publishing Inc., a corporation with principle 

offices at Albany. Dougherty County, Georgia. and having general 

circulation within the area of Dougherty. Early, Clay, Calhoun, 

11, Miller, Randolph, 

that tfie '- -%* 

ich is affixed 

11 its editions for 

I 

CLASSIFIED =GAL CLERK 

Sworn to and subscribed before 

me at Albany, Georgia this , 31 5b 

126 NORTH WASHINGTON STREET 4 P.O. BOX 48 4 ALBANY, GEORGIA 31 7O2-W8 
-L-L I 

,,,,,~~",,,~~"~~~~r~"-CC-~CCCCLLLL~ 

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ids 1 

bdq, luly 30 thru Sunday, August 2,2009.Valid in Georgia only. 

IFF SIOREWIDE REGULAR SALE & . CLEARANCE MERCHA~DISE INCLUO~NG HOME 

5' 

lam I8 hwrrby glum that, purswml lo the 

'lorlly set foM bdow, the Envlronmenlal 

Iwtion DlvIslon (hs~lnaftw, 'EPD") 01 the 

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: he magic of - TCJCVS a 
seqionaJ Ihw.. 1 

-.ledger-enquirer.com WEDNESI)AY, JULY 29,2009 Legal Notices 1 u 

chair net 

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KNGTON - Tf your 

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r, here's a small cormla 

5the did Fed Chairman 

hnanke's. 

nation's top hmdal ofm his net worth fall by 

lan a quarter in 2008, to 

n $850,000 and $1.9 mil- 

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form reM Tuesdayesday 

e dl suhtantial, that's 

rom the$12 don to 

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mke, who has had to 

? with a hand crisis 

toninptbymplex 

~Productsk~his 

h plain vanilla vehicl~ 

retirrment ph, mutw 

Hoticeis hcr&gkpn that. purwanf to 

authorltystll fxlh beb, the Enfrmrnm:al 

Pmtcction 31vmntncreInaltnr. EFS"l0f lfi@ 

Gcoqi~ Depsrmcrrt al Na!ural Re~mrn Or* 

(~~:~*.~mendmcritr to G~rqia'55tdte Imdmrntatl~ Plan (SIPj. Thr promwd rw;cloil k 

1 

dncrikd bdw: 

To pmuidf the pMC m WfbIttLWltY to tom- ment upim.~id pmui@ Input Into tlic pr~pjed 

SIP rcvohn. a puhllc heminpwill be hclM 3t 

5:Wil p.m. cnhrqusr 17.2009. In the EFO irain- mq Centtr Iacaled at 4744 rntemallon;lI Parkway. Suite 116, htlmtnta,Cewgia 103%. M!he 

Cearir.~. anynrc may umenl da!& rtlakF a natcmw:. cmmcn: cr oft~r avicwub~nt ur arqumelt aithcr orally or In writ(? Lm(rthy 

itat*eenk sr y!alcmvnlsnl cnnrtdcrablr t~h. 

nm or ecnnomrc IiXbrC, aswcII zrpreywu5fr 

recorded m?w~gts. mlrr! tte s~h~nrtlcd m dtlrrg fur ik offic~d rr~~td. 0:al su!cmmE s'lnc.!d hc cooci!& 

ATE OF GEORGIA 

:OUHTY OF MUSCOGEC )1 THE PROMTE COURT 

)F SAIg SffiTF bND COUNTY 

io lhc Crc4ito.s ol 

WlCE JEAHCTl E CAMPBELL KENT. 

1r;eased. 

55 285,006 mil Under the proff;un, file M- wOM~S H, BRAMLEY, lR. Sl&K OF GEOPGlh 

~tln~~v lrl'w 011 !Ilk E-lc fit ,WNlY Ti M~%OGEE 

he gazIer cannot he re- uanirln :.,IN G~AYTLE~ Ill TYi Fl'3RliE COllRT OF 5hi0 5iE.Tf. hm117 CWW 

le car industry a little $300 +. in a by hc dealer and tr;l& ;.;:; d;;;:i:r:ocn Tnlh. frrdr,.ln nl 
State of Georgia 

Department of Natural Resources 

Environmental Protection Division 

Air Protection Branch 

Part 70 Operating Permit Amendment 

Permit Amendment 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) 

Mailing Address: P. 0. Box 44 

Cedar Springs, Georgia 39832 (Early County) 

ParentlHolding Georgia-Pacific Corpotation 

Company: 

Facility AIRS Number: 04-1 3-QW-OOOO~ 

In accordance with the provisions of the Georgia Air 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 

described above is issued a construction permit for: 

Limit SO2 emissions from Power Boilers No. 1 and 2 to 135 lbhr each and limit Recovery Boiler No. 3 

SOZ emissions 20 350 ppm on a dry basis corrected to 8 percent oxygen when firing black liquor to 

comply with BART regulations. 

This Permit Amendment sbll also serve as a final amendment to the Part 70 Permit unless objected to by the 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 

condition of this Permit Amendment and Permit No. 2631-099-0001-V-02-0 Unless modified or revoked. this Permit 

Amendment expires upon issuance of the next Part 70 Permit for this source. 

This Perrnit Amendment may be subject to revocation, suspension, modification or amendment by the Director for 

cause induding evidence of noncompliance with any of the above; or for any misrepresentation made 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 

supporting data; or for any alterations affecting the emissions from this source. 

This Permit Amendment is further subject to and conditioned upon the terns, conditions. limitations, standards. or 

schedules contained in or specified on the attached f 1 pages. 

e Dire 

Environmental Protection Division 
Title V Permit Amendment 

Georgia-Pacific Corporation- Cedar Springs Operation Permit No . . 263 1-099-000 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 . . Process Descnptlon of Modification ........................................................................ 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 Operating Llmits ................................................................................ 3 

REQUIREMENTS FOR TESTING ....................................................................................... 4 

Specific Testing Requirements ............................................................................................................ 4 

REQUIREMENTS FOR MONITORING (Related to Data Collection) ................................ 5 

Specific Monitoring Requirements ...................................................................................................... 5 

OTHER RECORD KEEPING AND REPORTING REQUIREMENTS .................................. 7 

General Record Keeping and Reporting Requirements ............................................................. ......... 7 

Specific Record Keeping and Reporting Requirements ....................................................................... 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 ScheduleProgress Reports 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 ..................................................................... 1 1 

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

Title V Permit Amendment 

Georgia-Pacific Corporation- Cedar Springs Operation Permit No.: 263 1 -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 the boilers, or the equivalent. 

Limit the SO2 emissions from the recovery boiler to 350 ppmv on a dry basis corrected to 8 percent 

oxygen when firing black liquor for the complete 24-hour block period. 

Install CEMS on Recovery Boiler No. 3 to monitor SOz emissions. 

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 TO THE ENTIRE FACILITY 

Facility Wide Emission Caps and Operating Limits 

None Applicable. 

Facility Wide Federal Rule Standards 

None Applicable. 

Facility Wide SIP Rule Standards 

None Applicable. 

Facility Wide Standards Not Covered by a Federal or SIP Rule and Not Instituted as an 

Emission Cap or Operating Limit 

None Applicable 

Page 1 of 11 
Title V Permit Amendment 

Georgia-Pacific Corporation- Cedar Svrinw O~eration Permit No.: 263 1-099-0001 -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 or based 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 Boiler No. 1 

Power Boiler No. 2 

Recovery Boiler No. 3 

Specific Lirnitatio 

- 

nqu~rerncnts~~~ranuar~~s - - - - . . . - - - - - . . 

40 CFR 61 Subpart E 

40 CFR 63 Subpart DDDDD 

40 CFR 64 

391 -3-1 -.02(2)@) 

391 -3-1 -.02(2)(d) 

391 -3-1 -.02(2)(g) 

40 CFR Part 5 1 Append~x Y 

40 CFR 61 Subpart E 

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 5 1 Appendix Y 

40 CFR 63 Subpart MM 

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 5 1 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, 6.2.1 8 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 4.2.1 1,4.2.27, 

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 

ID No. --- 

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 Scmbber with 

Caustic solution as scrubbing 

media or limestone injection 

system 

Multicyclone 

Ventun Scrubber with 

Caustic solution as scrubbing 

media or limestone injection 

system 

Dry Bottom Electrostatic 

Precipitator 

Page 2 of 11 
Title V Permit Amendment 

Georgia-Pacific Corporation- Cedar Springs Operation Permit No.: 263 1 -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 firing black liquor solids, Sulfur dioxide emissions in excess of 350 ppm on a 

dry basis corrected to 8 percent oxygen as a block 24-hour period beginning each 

calendar day at 12 midnight or other appropriate starting times as may be specified or 

approved by the Division. 

[40 CFR Part 5 1 Appendix Y-BART] 

[Modified Permit Condition] 

3.2.8 The Permittee shall bum no more than 10,000 pounds per hour and 120 tons 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 of 40 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 5 1.308(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 11 
Title V Permit Amendment 

Georgia-Pacific Corporation- Cedar Springs Operation Permit No.: 263 1-099-0001 -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 1 
Title V Permit Amendment 

Georgia-Pacific Corporation- Cedar Springs Operation Permit No.: 263 1-099-0001 -V-02-6 

PART 5.0 REQUIREMENTS FOR MONITORING (Related to Data Collection) 

5.2 Specific Monitoring Requirements 

[Modified Permit Condition j 

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) of the 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 of the completion of the BART Exemption Project 

[40 CFR Part 51,40 CFR 63 Subpart MM; 40 CFR 63.864(d); Georgia Rules 391-3-I-. 

02(2)(b) and 39 1 -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) of the Division's monitoring requirements. 

[Georgia Rule 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 Codes US00 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, of 40 CFR 64.7, 64.8, and 64.9. 

[40 CFR 641 

PM 

PM 

PM 1 

Page 5 of 1 1 
Title V Permit Amendment 

Georgia-Pacific Corporation- Cedar Springs Operation Permit No.: 263 1 -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 - 

Indicator No. 3 1 Sc~bbant Flow RmJc 

A. Data The flow rate is 

Representativeness measured using standard 1 [64.3@)(1 )I 1 instrumentation provided for this purpose. 

B. Verification of 

Operational Status 

(newlmodified 

monitoring equipment 

only) 

[64.3(b)(2)] 

iiilicaf or No, 2 'r- . - 

'rwurc Drop Across 

;cn~ hbcr 

C. QNQC Practices 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 following procedures and requirements: 

[Georgia Rule 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 60 days of completion of the RATA. 

3-hour average. 

b. A cylinder gas audit shall be conducted at least once every quarter in accordance with 

Appendix F of 40 CFR 60. 

3-hour average. 

c. CEMS drift checks shall be conducted daily in accordance with 40 CFR 60.13(d). 

Page 6 of 1 1 
Title 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 

shall be reported: 

[391-3-1 -.O2(6)(b)l and 40 CFR 70.6(a)(3)(i)] 

a. Excess emissions: (means for the purpose of this Condition and Condition 6.1.4, any 

condition that is detected by 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 350 ppm on a dry basis corrected to 

8 percent oxygen when firing black liquor only for the complete 24-hour 

period. 

[40 CFR 5 1.308(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 SO2 concentration, 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 135 Ibs per 

hour. 

[40 CFR 5 1.308(e)] 

Page 7 of 11 
Title 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 Boilers No. 1 and 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 72 hours following 

the end of that calendar day. The equations to be used for each calculation follow. 

[Avoidance of 40 CFR 52.2 11 

a. SAM Emissions: 

Ibhr SAM ~M,'o"= T[(SAM Emission Factor,---- X SO, Emission Rate, ,- day i=, Ibhr SO, 

b. PM Emissions: 

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

hr 

c. NOx Emissions: 

d. CO Emissions: 

24 

D5CF 20.9% CO Conci,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 2,000 Ib 

e. SO2 Emissions: 

24 

so2.~= z[(F - Factor,,- 20.9% SO2 Conc,, 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% 1 hour average SOZ Conc,, lb (~~rtlow DSCFh, -- i 20 9%-01% X I 06/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 Springs Operation Permit No.: 263 1-099-0001-V-02-6 

For the purposes of this condition, the variable i represents hour i of the calendar day and 

any emission factors, airflow or F-factors used in the above calculations will be established 

upon the most recent Division-approved performance testing. 

[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 SO2 for 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~ dayof the 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 of record. 

[Avoidance of 40 CFR 52.21,40 CFR 51.308(e)] 

Page 9 of 11 
Title V Permit Amendment 

Georgia-Pacific Corporation- Cedar Springs Operation Permit No.: 2631 -099-0001-V-02-6 

PART 7.0 OTHER SPECIFIC REQUIREMENTS 

7.1 Operational Flexibility Associated with this Amendment 

7.2 Off-Permit Changes Associated 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 Sources Associated 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" of the Permit application and White Paper #1) 

Not Applicable. 

7.7 Compliance ScheduleIProgress Reports Associated with this Amendment 

[39l-3-l -.O3(l O)(d)3 and 40 CFR 70.6(~)(4)] 

None applicable. 

7.8 Emissions Trading Associated 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 10 of 11 

Air Qaalikfe-mit hnbe@s) 

263 1-099-0001 -V-02-5 

-.\- 

_Dates &f OnglnalJe@ Iaunnie~r ~ni&in'dhe~t - Feb 24,2009 
Title V Permit Amendment 

Georgia-Pacific Corporation- Cedar Springs Operation Permit No.: 263 1-099-0001 -V-02-6 

7.13 Pollution Prevention Associated witb this Amendment 

Not Applicable 

7.14 Specific Conditions Associated with this Amendment 

[New Permit 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 11 of l l 
Georgia Department of Natural Resources 

Environmental Protection Division Air Protection Branch 

4244 International Parkway Suite 120 Atlanta Georgia 30354 

4041363-7000 Fax: 4041363-71 00 

Chris Clark, Commissioner 

F. Allen Barnes, Director 

December 1 1,2009 

MEMORANDUM 

To: F. Allen Barnes, Director 

Environmental Protection Division 

From: James Capp, Chief 

Air Protection Branch 

Subject: Responses to 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:klc 
State of Georgia 

Responses to 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 comments were received during the public hearing. 

Written Comments 

Comments were received from EPA, Region 4 and from the U.S. Fish and Wildlife Service 

and National Park Service of the Department of 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 in Appendix 0. EPA comments 

are presented verbatim below with respective responses. The response to EPA Key 

Comment 3 also responds to a portion of the DO1 comment. 

I. Key Comments: The following comments must be addressed in the SIP to meet the 

requirements of 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 be 
enforceable by the State. In this 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 permits for 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. 

Providing the 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. 

If the 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 has the necessary legal authority under State law to adopt and implement the State's 

Regional Haze SIP, including the 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 Comment 2: Georaia Pacific Cedar Sprinas BART Exemption Determination. 

"Georgia Pacific Cedar Springs was exempted from BART because the 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, 201 1. 

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 progress for this facility. 
EPA is concerned with the compliance date of July 30, 201 1. 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 below the significance level, or for the 

State to include a BART determination for the currently BART-eligible source in its Regional 

Haze SIP submitted to 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 need for an actual 

determination and is subject to different considerations. 

Please provide your reasoning for concluding that extending the date for the BART 

exemption to July 30, 201 1, was appropriate in this instance and how the 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 

communication to 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's wastewater 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 201 1 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. In addition 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 haze 
compliance date of July 30, 201 1. Adding 18 months and 36 months to 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 presented for 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 recommends you 

prepare an air quality analysis assessing the 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 concerns were addressed during the formal Federal Land Manager 

consultation required by the rule in Appendix 0, the response to EPA1s comment also 

effectively addresses the 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 helpful to more clearly portray the information presented. 

SIP Narrative - Main Report: 

SC Narr Comment I: Page ii of Executive Summary and Page 12 - BestWorst Visibility 

Da vs. 

"Please notate on page ii of the Executive Summary and page 12 of the SIP Narrative the 

location of a list for 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 1 Areas: 

"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 

percent Worst Days (deciviews)'." 

EPD Response: 

The header was corrected 

SC Narr Comment 3: 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. 

"The following 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 narrative was 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 201 6 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 narrative was revised as suggested. 

SC Narr Comment 6: Page 91 - Temple-Inland Rome 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 reasonable at 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 on the impacts on visibility, should be provided in the 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 predicted to meet the 

Uniform Rate of Progress in 2018 with controls that are already on the books was 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 

in Table 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 

revised to 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 projections without 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 upon the 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: 

SC Appendix 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 

process for 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. 

SC Appendix 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 in the 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. 

SC Appendix 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-02-0 on April 15, 2009. The text of Appendix H 

has been revised accordingly. 

SC Appendix 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 between the States 

of Georgia and Florida. Please list each of these emission units and state how the two 

States resolved the approach to addressing Florida emission units identified by Georgia's 
method (and the 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 L LC 

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 was performed. No additional costeffective controls were idenitied. 

Unit was identified by GA and 4-factor 

analysis was performed. 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 first 
Regional Haze planning period (ending in 2018). 

No changes have been made to the proposed SIP in response to this comment. 

SC Appendix J Comment 2. b: Page 3. 

"The table 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 included for 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.