Appendix H.10 

Supporting Data for Four-factor 

Analyses 

H.10 - 1 
Georgia EPD requested four-factor analyses from SO2 point sources for 

emissions units identified as likely to contribute 0.5% or more to the total visibility 

impairment caused by sulfate at any Class I area in 2018. Analyses were 

received for a total of 15 emissions units. The units and the corresponding fourfactor analysis submittal dates are presented in Table H.10-1. For some 

emissions units additional data was submitted at the request of EPD or at the 

initiative of the facility. The submittals have been saved with Georgia EPD’s 

Regional Haze files. They are available to the public for inspection during normal 

business hours of 8:00 a.m. to 4:30 p.m. at the Georgia Environmental Protection 

Division, Air Protection Branch, 4244 International Parkway, Suite 120, Atlanta, 

Georgia 30354. 

 

Table H.10-1. Submittal Dates and Worksheets for Four-factor Analyses 

Facility Emissions Unit Submittal 

Date(s) 

Summary 

Worksheet 

GA Pacific Brunswick Cellulose Power Boiler No. 4 7-2-07 

9-7-07 

10-20-07 

10-10-08 

10-15-08 

H.10-1 

GA Pacific Brunswick Cellulose Recovery Boiler No. 6 

(M24) 

7-2-07 

9-17-07 

1-17-08 

H.10-2 

GA Pacific Cedar Springs Power Boiler No. 1 

(U500) 

7-2-07 

9-17-07 

1-17-08 

H.10-3 

GA Pacific Cedar Springs Power Boiler No. 2 

(U501) 

7-2-07 

9-17-07 

1-17-08 

H.10-4 

GA Pacific Cedar Springs Recovery Boiler No. 3 

(R402) 

7-2-07 

9-17-07 

1-17-08 

7-31-08 

8-15-08 

H.10-5 

GA Pacific, Savannah River Mill Boiler No. 3 (B001) 7-2-07 

7-16-07 

H.10-6 

GA Pacific, Savannah River Mill Boiler No. 4 (B002) 7-2-07 

7-16-07 

H.10-7 

GA Pacific, Savannah River Mill Boiler No. 5 (B003) 7-2-07 

7-16-07 

H.10-8 

Georgia Power Plant Kraft Steam Generator 1 7-12-07 

9-7-07 

H.10-9 

Georgia Power Plant Kraft Steam Generator 2 7-12-07 

9-7-07 

H.10-10 

Georgia Power Plant Kraft Steam Generator 3 7-12-07 

9-7-07 

H.10-11 

Georgia Power Plant McIntosh Steam Generator 1 7-12-07 H.10-12 

H.10 - 2 
9-7-07 

Georgia Power Plant Mitchell Steam Generator 3 7-12-07 

9-7-07 

H.10-13 

Internat. Paper, Savannah Mill Power Boiler 13 6-29-07 

10-11-07 

H.10-14 

Temple-Inland Rome Linerboard Power Boiler No. 4 6-29-07 

11-11-08 

H.10-15 

A summary worksheet (compiled by EPD) of each emissions unit analysis 

submitted by the facilities is presented below. Following the individual emissions 

unit worksheets are a summary worksheet for emissions units in south Georgia 

(which affect Okefenokee and Wolf Island) and a summary worksheet for 

emissions units (there is only one) in north Georgia (which affect Cohutta). The 

south and north Georgia worksheets include visibility improvement metrics. 

Table H.10-2 contains notes of explanation for selected fields and cells in the 

four-factor analysis spread sheets. 

Table H.10-2. Four-Factor Analysis Worksheets: Explanatory Notes 

 

Field Data 

Source 

Notes 

Class I sulfate 

impact 

fraction 

Georgia 

EPD 

This is the impact of sulfate emissions from the 

specific emissions unit on visibility in the specified 

Class I area, expressed as a fraction of the 

combined sulfate impacts of all of the impacting 

facilities in the Area of Influence. The impact given 

is based on the VISTAS SO2 projected 2018 

emissions. Threshold for inclusion in 4-factor 

analysis was impact of 0.005 (0.5 %) or more. 

4F baseline 

SO2 

company The baseline emissions used by the facility in the 4-

factor submittal. In the cases of U500 and U501 at 

GA Pacific Cedar Springs, the number represents 

emissions after an existing venturi scrubber with 

water scrubbant (they estimate 30% SO2 control). 

In the case of GA Pacific Savannah River, all 3 

emissions units currently perform limestone 

injection for SO2 removal. 

Baseline 

basis 

company In many instances the company used a different 

baseline emissions level than the VISTAS 

projected value. A blank field means that the 

company did not provide a full evaluation and that 

the VISTAS value has been inserted into the 

baseline field. 

H.10 - 3 
Field Data 

Source 

Notes 

Control 

Technology 

company Control, deemed technically feasible by the facility, 

evaluated for reduction of SO2 emissions. 

Control 

Effectiveness 

company Percent reduction as presented in the facility’s 4-

factor analysis. In cases where the facility did not 

list a control effectiveness, this was back-calculated 

from the tons of reductions. 

Annual cost, 

company 

company Company cost estimates were typically prepared as 

study-level estimates, accurate to within +/- 30 

percent. The costs are assumed to be in 2007 

dollars (some companies stated this explicitly). 

The annual cost is the sum of the annual operation 

and maintenance cost and the total installed cost 

(capital cost), annualized over the life of the project. 

Project lives ranged from 15 to 20 years, interest 

rates from 7% to 10%, and capital recovery factors 

from 0.094 to 0.117. 

Cost/ton calculation The annual cost divided by the tons reduced from 

the 4F baseline. 

Annual Cost, 

ACNet 

Air Control 

Net 

The estimated annual cost from a query of EPA’s 

Air Control Net database. The costs listed came 

from queries which found matches for the 

applicable technology at the specific unit and 

facility. The queries provide estimates in 2004 

dollars. This number was then escalated to 2006 

dollars using the Chemical Engineering Plant Cost 

Index. 

Statutory 

factors 

Company A “0” indicates that the submittal provided no 

information pertaining to the specific factor. A blue 

cell indicates that the company has indicated that 

the option could be implemented prior to Jan. 1, 

2012. This would allow the control measure to be 

in place during all 5 years that visibility data will be 

collected for the 2018 Regional Haze progress 

report. The expected useful life of all of the 

emissions units is 2018 or later. 

Visibility 

Sensitivity: 

Tons 

SO2/Mm-1

Georgia 

EPD 

The tons of SO2 required to effect a reduction of 1 

Mm-1 (inverse megameter) in the applicable Class I 

area. This value is independent of the control 

technology. 

Visibility 

Sensitivity: 

$106

/Mm-1

Calculation The cost, based on the specific technology, to 

effect a reduction of 1 Mm-1 (inverse megameter) in 

the applicable Class I area. This is the product of 

$/ton and ton/ Mm-1. 

H.10 - 4 
Field Data 

Source 

Notes 

Visibility 

Sensitivity: 

Mm-1

Calculation The extinction reduction (visibility improvement) in 

Mm-1 that would be achieved in the applicable 

Class I area by implementation of the specific 

control. An orange cell indicates an extinction 

reduction of greater than 0.010 and less than 

0.100. A light green cell indicates an extinction 

reduction of greater than 0.100. 

Abbreviations Used: 

ACNet – Air Control Net 

acfm – actual cubic feet per minute 

CRF – capital recovery factor 

dscfm – dry standard cubic feet per minute 

Mm-1 (inverse megameter) 

Following the summary worksheets of the four-factor analyses are copies of the 

original facility submittals. Followup submittals (if applicable) from the facilities 

may be inspected at the offices of Georgia EPD’s Air Protection Branch as noted 

above. 

H.10 - 5