1 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 supplem ental 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 ti me 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 request s 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 approve d into the SIP non-SIP rules referenced and relied upon in these infrastructure submissions . These statutes, stat e 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 a nd document specific subsections citations to document compliance with requirements for elemen ts 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 regulator y citations that govern the St ate’s SIP-approved minor source permitting program, including clarification that Georgi a 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 questi ons regarding Georgia’s permitting fee framework/program:2 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, pl ease provide more detailed information on the state’s permitting fee struct ure 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 revi ew (NNSR) permits (i.e. single or combination of permit-specific fee charged to th e applicant, a state tax, legisla tive 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, stat ute). Please cite (and provide an electronic copy) all re levant state and SIP-approved regulations or statutes that require/mandate funding for processing PSD and NNSR permits. Please no te specific fee amount s 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, implementati on and enforcement of PSD and NNSR permits and are sufficient to operate the state’s permitting program.

 Additionally, include a st atement that the title V operating program fees cover the reasonable cost of implementation and enforcement of PSD and NN SR permits after they have been issued.

We look forward to continuing to work with Georgia a nd thank you in advance for you r assistance with this. Let us know if you have any questions.

Twunjala

Twunjala Bradley Air, Pesticides and Toxi cs Management Division 61 Forsyth Street, SW Atlanta, Georgia 30303 phone: (404) 562-9352 fax: (404) 562-9019
emai: bradley.twunaja@epa.gov