Environmental Protection Division Air Protection Branch 

4244 International Parkway Suite 120 Atlanta Georgia 30354 

4041363-7000 Fax: 4041363-71 00 

Mark Williams, Commissioner 

Judson H. Turner, Director 

Beverly H. Banister 

Director: Air, Pesticides, and Toxics Management Division 

U.S. EPA, Region 4 

6 1 Forsyth Street 

Atlanta, Georgia 30303 

Re: Clarification of lntent to Withdraw RACT Rules 

Dear Ms Banister: 

This letter is being sent to clarify the Georgia Environmental Protection Division's (GA EPD) intent 

concerning the withdrawal of a revision to the State Implementation Plan (SIP). 

On November 13, 1992, GA EPD submitted to the Environmental Protection Agency (EPA), a revision to 

the SIP to incorporate rules for generic oxides of nitrogen (NOx) and volatile organic compound (VOC) 

reasonably available control technology (RACT) into the SIP. Specifically, these rules were Georgia Rule 

391-3-1-.02(2)(tt) for VOC RACT and Georgia Rule 391-3-1-.02(2)(yy) for NOx RACT. 

EPA took the position that RACT rules without emission limits could not be approved into the SIP. 

Therefore, on December 22, 1997, GA EPD submitted a letter to EPA withdrawing the SIP revision 

submittal that incorporated the generic VOC and NOx RACT rules. The intent of this letter was to only 

withdraw the submissions of Georgia Rule 391 -3- 1 -.02(2)(tt) and Georgia Rule 391 -3-1 -.02(2)(yy) from 

approval as a revision to the SIP. No other rules submitted with the November 13,1992 submittal were 

affected by the December 22, 1997 withdrawal request. 

If you have any questions or need more information, please contact Jimmy Johnston at (404) 363-7014 or 

via email at jimmy.johnston@dnr.state.ga.us. 

Sincerely, 

Georgia Environmental Protection Division 

JAC: klc 

c: Scott Davis, U.S. EPA Region 4 

Lynorae Benjamin, U.S. EPA Region 4 

Sara Waterson, U.S. EPA Region 4 
. . 

December 22, 1997 

* Georgia Department, Natural Resources 

205 Butler Street, S.E., East Floyd Tower, Atlanta, Georgia 30334 

Lonice C. Barrett, Commissioner 

Harold F. Reheis, Director 

Environmental Protection Division 

4041656-47 13 

Mr. John H. Hankinson 

. Regional Administrator 

U.S. EPA, Region 4 

61 Forsyth Street 

Atlanta, Georgia 30303 

Dear Mr. Hankinson: 

On November 13, 1992, we submitted to you a revision to the State 

Implementation Plan (SIP) to incorporate generic oxides of nitrogen (NO,) and volatile 

organic compound (VOC) reasonably available control technology (RACT) rules. EPA 

took the position that RACT rules without emission limits could not be approved into 

the SIP. Therefore, on November 15, 1994, we submitted source specific permits' 

that required NO, and VOC RACTon the same sources that would have been subject 

to the generic RACT rules. As a result, there is.no need to act on the generic NO, 

and VOC RACT rules contained in the November 13, 1992 request. At this time, we 

would like to withdraw the N_ovember-3-3;~2 .. -- . . . .__ _ ______ . request. 

Please contact me if there are any questions about this matter. 

Sincerely, 

Harold F. Reheis 

Director 
Georgia Department Natural Resources 

205 Butler Street, S.E., East Floyd Tower, Atlanta, Georgia 30334 

! Joe D. Tanner, Commissioner 

Harold F. Reheis, Director 

Environmental Protection Division 

November 13, 1992 

Mr. Greer Tidwell 

Regional Administrator 

U.S. Environmental Protection Agency 

345 Courtland Street, NE 

Atlanta, Georgia 30365 

Dear Mr. Tidwell: 

By copy of this letter, we are supplying to Winston Smith two 

copies of the various State regulations, SIP commitments and 

narratives regarding ozone SIP requirements for the Atlanta area 

due by November 15, 1992 to satisfy the Clean Air Act. We 

appreciate the helpful comments and reviews that Region IV has 

provided to our staff in the development of these regulations and 

operating program procedures. We look forward to continued close 

discussion and cooperation as other programs and further details 

need to be developed. 

It is our understanding that the material being submitted is 

satisfactory and approvable by EPA in meeting the Clean Air Act 

requirements at the current time. 

Although not required for EPA approval, Region IV has given us 

some comments as to preferences on certain program operating 

procedures. We will seriously consider those suggestions and work 

further with your staff on at least some of them. As required for 

EPA approval, as stated in Region IVis official comments for our 

public hearing on these matters, we have added an SIP narrative for 

Stage I1 implementation dealing with public education, enforcement 

'and training. With regard to the annual emissions statements from 

point sources of VOC and NO, in the Atlanta area, we already have 

adequate authority 'to require that the affected sources sign a 

certification statement when the data is submitted to us. This 

will be done. 
Mr. Greer Tidwell 

Page 2 

November 13, 1992 

The committal schedule for development of the enhanced vehicle 

emission testing program in Atlanta includes timeframes which EPA 

indicated were needed to gain EPA's acceptance of that commitment. 

We .will work diligently to meet the various actions and time 

deadlines. If matters beyond our control create any delays, we 

will inform ~egion IV and work out the best possible new schedule. 

It appears this may be needed because we understand some EPA 

interpretations and the final requirements issued by EPA on 

November 5 may have already changed from the dates Region IV had 

initially indicated as needed. The bottom line is that we will do 

what is actually needed as soon as it is practical to do properly. 

Although the public hearing notice did not specifically highlight 

or mention the I&M committal schedule, it was covered in that 

notice in referring to ozone SIP requirements, was available for 

public review 30 days before the hearing and was discussed during 

that hearing. I understand that EPA will be able to accept this 

schedule either as a letter commitment (which we are hereby making) 

or as an SIP revision, assuming you conclude that the required SIP 

notice and review requirements have been satisfied. 

Enclosed with the SIP package are certifications that the 

required public notices in the newspapers were provided, hearings 

held and comments received on these proposals, in satisfaction of 

the federal SIP-processing regulations. We have also enclosed the 

administrative materials and technical support to satisfy the SIP 

submittal completeness criteria checklist. 

With regard to the 1990 baseline inventory for the 13-county 

ozone nonattainment area around Atlanta, we understand that this 

fixed level of emissions (adjusted as required) will be the base 

against which percent reduction requirements will be gaugedto meet 

the Clean Air Act requirements concerning VOC controls. It is 

recognized that for SIP modelling and overall strategy development, 

this inventory may need updating to use improved calculation and 

projection methods (Mobile 5 and other improvements). We are 

committed to doing so for SIP development purposes. However, we 

understand that inventory updating for SIP strategy needs will not 

change the Itfixed" 1990 adjusted baseline inventory, used for 

percent reduction requirements. 

The off-road mobile emissions shown in the 1990 inventory for 

Atlanta are those furnished to us recently by EPA (prepared by a 

contractor). Since we have not been given adequate information to 

understand the basis of this part of the inventory, we reserve the 

right (upon receipt of such information) to make some changes to 

it. It is not likely these would be significant. 
Mr. Greer Tidwell 

Page 3 

November 13, 19 92 

We look forward to prompt review and approval by EPA of these 

submittals. If you or your staff desire detailed explanations or 

interpretations of any point, please do not hesitate to contact Bob 

Collom of the ~ir Protection Branch. 

Sincerely, 

~arold F. ~&eis 

Director 

HFR:njj 

cc: Winston Smith (w/enclosures) 

Bob Collom