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Ward, Nacosta

From: Johnston, Jimmy <Jimmy.Johnston@dnr.state.ga.us>

Sent: Friday, July 25, 2014 4:21 PM

To: Bradley, Twunjala

Cc: Vanjani, Taruna; Ward, Nacosta; Lakeman, Sean; Benjamin, Lynorae; Bentley, Keith; 

Hays, Karen

Subject: RE: Infrastructure SIP Supplemental Information

Attachments: Additional information for 2008 PB & O3 and 2010 SO2 & NO2 7172014.docx

Attached is the additional information that you requested regarding Georgia’s 110(a)(2) infrastructure SIPs for the 2008

ozone and lead NAAQS and 2010 sulfur dioxide and nitrogen oxides NAAQS.  Please let us know should you require any

further information.

From: Bradley, Twunjala [mailto:Bradley.Twunjala@epa.gov] 

Sent: Tuesday, June 17, 2014 12:21 PM 

To: Johnston, Jimmy 

Cc: Ward, Nacosta; Lakeman, Sean; Benjamin, Lynorae 

Subject: Infrastructure SIP Supplemental Information 

Hi Jimmy, 

Please see below the 110(a)(2) infrastructure supplemental information we discussed today on the monthly 

conference call. 

Over Arching comments for all submissions and elements: 

 The September 2013 ISIP Guidance states that any time the state is relying on any rule or statute 

not approved in the state’s federally-approved SIP, a copy of that rule or statute should be 

provided in the infrastructure SIP. EPA requests Georgia supplement its 110(a)(2) Infrastructure 

SIP submittals for the 2008 lead and 8-hour ozone and the 2010 SO2 and NO2 NAAQS with a 

CD/or website links containing the text of any statutes, state law, or state regulations not 

submitted for incorporation/not currently approved into the SIP non-SIP rules referenced and 

relied upon in these infrastructure submissions. These statutes, state laws, and/or state 

regulations are not being submitted for incorporation into the SIP. 

 While Georgia cites the Georgia Air Quality Act: Article 1: Air Quality (O.C.G.A. Section 12-9, 

et seq.) EPA requests that the state identify and document specific subsections citations to 

document compliance with requirements for elements 110(a)(2)(A), (B), (E)-(H), (J), (K) and 

(M) for the 2008 Lead and 8-hour Ozone, 2010 NO2 and SO2 NAAQS. 

110(a)(2)(C) – Please provide the regulatory citations that govern the State’s SIP-approved minor source 

permitting program, including clarification that Georgia has a SIP-approved minor new source review 

permitting program that covers compliance with 110(a)(2)(C) for all relevant NAAQS infrastructure SIP 

submissions (i.e. 2008 8-hour ozone & lead and 2010 NO2 & SO2 NAAQS). 

110(a)(2)(L) – Please respond to the following questions regarding Georgia’s permitting fee 

framework/program: 
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In addition to the current title V information provided in Georgia’s existing infrastructure submissions for the 

2008 8-hour ozone & lead and 2010 NO2 & SO2 NAAQS, please provide more detailed information on the 

state’s permitting fee structure with regards to the PSD and NNSR by providing responses and documentation 

to the questions below to demonstrate EPD’s compliance with 110(a)(2)(L). Please be sure to clarify that the 

documentation covers compliance for these relevant NAAQS infrastructure SIP submissions (i.e. 2008 8-hour 

ozone & lead and 2010 NO2 & SO2 NAAQS). 

 Identify the funding source(s) for the reasonable cost of review, approval, implementation and 

enforcement of PSD and nonattainment new source review (NNSR) permits (i.e. single or combination 

of permit-specific fee charged to the applicant, a state tax, legislative appropriations, title V operating 

fee program etc.) 

 Identify how this funding source is mandated or what gives the agency the authority to charge a fee or 

require funding (i.e. state law, SIP-approved regulation, legislation, statute). Please cite (and provide an 

electronic copy) all relevant state and SIP-approved regulations or statutes that require/mandate funding 

for processing PSD and NNSR permits. Please note specific fee amounts are not required for 

documentation. 

 Document if possible that the current permitting fee structure in place for PSD and NNSR reflect the 

reasonable cost of review, approval, implementation and enforcement of PSD and NNSR permits and 

are sufficient to operate the state’s permitting program. 

 Additionally, include a statement that the title V operating program fees cover the reasonable cost of 

implementation and enforcement of PSD and NNSR permits after they have been issued. 

We look forward to continuing to work with Georgia and thank you in advance for your assistance with this. 

Let us know if you have any questions. 

Twunjala 

Twunjala Bradley 

Air, Pesticides and Toxics Management Division 

61 Forsyth Street, SW 

Atlanta, Georgia 30303 

phone: (404) 562-9352 

fax: (404) 562-9019 

emai: bradley.twunaja@epa.gov