Environmental Protection Division Air Protection Branch 4244 International Parkway Suite 120 Atlanta Georgia 30354 4041363-7000 Fax: 4041363-7100 Mark Williams, Commissioner Judson H.Turner, Director

BeverlyH. Banister Director: Air, Pesticides,and Toxics ManagementDivision U.S. EPA, Region 4 6 1Forsyth Street Atlanta, Georgia30303
Re: Clarificationoflntentto Withdraw RACTRules
DearMs Banister:
This letter is being sentto clarify the Georgia EnvironmentalProtectionDivision's (GA EPD) intent concerningthe withdrawal of arevision to the StateImplementation Plan (SIP).
OnNovember 13, 1992,GA EPD submitted to the Environmental Protection Agency (EPA), arevision to the SIP to incorporate rules for genericoxides of nitrogen (NOx) andvolatile organic compound(VOC) reasonably available controltechnology (RACT) into the SIP. Specifically,these rules were GeorgiaRule 391-3-1-.02(2)(tt) for VOC RACT and Georgia Rule 391-3-1-.02(2)(yy)forNOx RACT.
EPAtook the position that RACTrules without emission limitscould notbe approved intothe SIP. Therefore,onDecember 22, 1997,GA EPD submitted a letter to EPA withdrawingthe SIP revision submittal that incorporated the genericVOC andNOx RACT rules. The intent ofthis letter was to only withdrawthe submissions ofGeorgia Rule 391-3- 1 -.02(2)(tt)and GeorgiaRule 391-3-1-.02(2)(yy) from approval as a revision to the SIP. No otherrules submitted with theNovember 13,1992submittalwere affectedby the December22, 1997 withdrawalrequest.
Ifyouhave any questions orneed more information,please contactJimmy Johnston at (404) 363-7014or viaemail atjimmy.johnston@dnr.state.ga.us. Sincerely,

Georgia EnvironmentalProtection Division
JAC:klc

c: Scott Davis,U.S. EPARegion4 Lynorae Benjamin,U.S. EPA Region4 Sara Waterson, U.S. EPA Region4

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December22, 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 4041656-4713

Mr. John H. Hankinson

. RegionalAdministrator U.S. EPA, Region 4 61 Forsyth Street Atlanta, Georgia 30303
Dear Mr. Hankinson: On November 13, 1992,we submittedto 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 RACTonthe same sources that would have been subject to the generic RACT rules. As a result, there is.noneed 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 IVisofficial 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 .willwork 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 (whichwe 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, 1992

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